Your privacy is critically important to us. At Cognitive Concierge, we have a few fundamental principles:
- We are thoughtful about the personal information we ask you to provide and the personal information that we collect about you through the operation of our services.
- We store personal information for only as long as we have a reason to keep it.
- We aim to make it as simple as possible for you to control what information on your website is shared publicly (or kept private), indexed by search engines, and permanently deleted.
- We help protect you from overreaching government demands for your personal information.
- We aim for full transparency on how we gather, use, and share your personal information.
Who We Are and What This Policy Covers
We ease the burden of navigating life decisions that accompany cognitive conditions so our clients can focus on participating in life more fully and independently. We are health and wellness meets technology, delivered through a simple, yet powerful web service. We believe that the diagnosis of a cognitive condition should be approached with the same level of rigor and care as those with any other chronic condition. We aim to make it so by delivering exceptional cognitive advocacy and enrichment programs.
- Our website (https://mycognitiveconcierge.com);
- Our mobile applications;
- Our other Cognitive Concierge products, services, and features that are available on or through our website (for example, Cognitive Concierge membership plans, Cognitive Destination Retreats and Cognitive Topical Retreats).
Below we explain how we collect, use, and share information about you, along with the choices that you have with respect to that information.
What Information We Collect and Why We Collect It
We only collect information about you if we have a reason to do so — for example, to provide our Services, to communicate with you, or to make our Services better.
We collect this information from three sources: if and when you provide information to us, automatically through operating our Services, and from outside sources. Let’s go over the information that we collect.
Information You Provide to Us
It’s probably no surprise that we collect information that you provide to us directly. Here are some examples:
- Basic account information: We ask for basic information from you in order to set up your account. For example, we require individuals who sign up for a Cognitive concierge account to provide their first and last name, an email address and password, and address.
- Payment and contact information: If you buy something from us — a Cognitive Concierge membership plan, a Cognitive Destination Retreat or a Cognitive Topical Retreat (thank you!), you will provide personal and payment information like your name, credit card information, billing address and contact information. We also keep a record of the purchases you’ve made.
- Content information: You might provide us with information about you in draft and published content (a blog post or comment that includes biographic information about you, or any media or files you upload).
- If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.
- Communications with us (hi there!): You may also provide us with information when you respond to surveys or contact forms, communicate with us about a support question, post a question in our public forums, sign up to receive updates about products and promotions or subscribe to our mailing list. When you communicate with us via form, email, phone, comment, or otherwise, we store a copy of our communications (including any call recordings as permitted by applicable law).
- Job applicant information: If you apply for a job with us — awesome! You may provide us with information like your name, contact information, resume or CV, and work authorization verification as part of the application process.
Information We Collect Automatically
We also collect some information automatically:
- Log information: Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, including the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Services.
- Usage information: We collect information about your usage of our Services. For example, we collect information about what happens when you use our Services (e.g., page views, hyperlink clicks, abandoned cart statistics and interactions with our Services) along with information about your device (e.g., screen size, name of cellular network, and mobile device manufacturer). We use this information to, for example, provide our Services to you, get insights on how people use our Services so we can make our Services better, and understand and make predictions about user retention.
- Location information: We may determine the approximate location of your device from your IP address. We collect and use this information to, for example, calculate how many people visit our Services from certain geographic regions. We may also collect information about your precise location via our mobile apps (like when you post a photograph with location information) if you allow us to do so through your mobile device operating system’s permissions.
- Stored information: We may access information stored on your mobile device via our mobile apps. We access this stored information through your device operating system’s permissions. For example, if you give us permission to access the photographs on your mobile device’s camera roll, our Services may access the photos stored on your device when you upload a really amazing photograph of the sunrise to your website.
- If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
- When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
- If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
Information We Collect from Other Sources
Third-party services may give us information, like mailing addresses for individuals who are not yet our users (but we hope will be!). We use this information for marketing purposes like postcards and other mailers advertising our Services.
How and Why We Use Information
Purposes for Using Information
We use information about you for the purposes listed below:
- To provide our Services. For example, to set up and maintain your account, host customized content, provide customer service, process payments and orders, and verify user information.
- To ensure quality, maintain safety, and improve our Services. For example, by providing updates to our Services. Or, for example, by monitoring and analyzing how users interact with our Services so we can create new features that we think our users will enjoy or make our Services easier to use.
- To place and manage ads. For example, to place ads on some parts of our website as part of our advertising program and to understand ad performance.
- To market our Services and measure, gauge, and improve the effectiveness of our marketing. For example, by targeting our marketing messages to groups of our users (like those who have a particular membership plan with us or have been users for a certain length of time), advertising our Services, analyzing the results of our marketing campaigns (like how many people purchased a membership plan after receiving a marketing message), and understanding and forecasting user retention.
- To protect our Services, our users, and the public. For example, by detecting security incidents; detecting and protecting against malicious, deceptive, fraudulent, or illegal activity; fighting spam; complying with our legal obligations; and protecting the rights and property of Cognitive Concierge and others, which may result in us, for example, declining a transaction or terminating Services.
- To fix problems with our Services. For example, by monitoring, debugging, repairing, and preventing issues.
- To customize the user experience. For example, to personalize your experience by serving you customized content and advertisements for our Services.
- To communicate with you. For example, by emailing you to ask for your feedback, share tips for getting the most out of our Services, or keep you up to date on Cognitive Concierge; texting you to verify your payment; or calling you to share offers and promotions that we think will be of interest to you. If you don’t want to hear from us, you can opt out of marketing communications at any time. (If you opt out, we’ll still send you important updates relating to your account.)
- To recruit and hire new Cognitive Concierge employees. For example, by evaluating job applicants and communicating with them.
Legal Bases for Collecting and Using Information
A note here for those in the European Union about our legal grounds for processing information about you under EU data protection laws, which is that our use of your information is based on the grounds that:
(1) The use is necessary in order to fulfill our commitments to you under the applicable terms of service or other agreements with you or is necessary to administer your account — for example, in order to enable access to our website on your device or charge you for a paid plan; or
(2) The use is necessary for compliance with a legal obligation; or
(3) The use is necessary in order to protect your vital interests or those of another person; or
(4) We have a legitimate interest in using your information — for example, to provide and update our Services; to improve our Services so that we can offer you an even better user experience; to safeguard our Services; to communicate with you; to measure, gauge, and improve the effectiveness of our advertising; and to understand our user retention and attrition; to monitor and prevent any problems with our Services; and to personalize your experience; or
How We Share Information
We share information about you in limited circumstances, and with appropriate safeguards on your privacy. These are spelled out below, as well as in the section called Ads and Analytics Services Provided by Others:
- Third-party vendors: We may share information about you with third-party vendors who need the information in order to provide their services to us, or to provide their services to you. This includes vendors that help us provide our Services to you (like Stripe payment providers that process your credit and debit card information, fraud prevention services that allow us to analyze fraudulent payment transactions, cloud storage services, postal and email delivery services that help us stay in touch with you, customer chat and email support services that help us communicate with you); those that assist us with our marketing efforts (e.g., by providing tools for identifying a specific marketing target group or improving our marketing campaigns, and by placing ads to market our services); those that help us understand and enhance our Services (like analytics providers); those that make tools to help us run our operations (like programs that help us with task management, scheduling, word processing, email and other communications, and collaboration among our teams); other third-party tools that help us manage operations; and companies that make products available on our Services, who may need information about you in order to, for example, provide technical or other support services to you. We require vendors to agree to privacy commitments in order to share information with them.
- Legal and regulatory requirements: We may disclose information about you in response to a subpoena, court order, or other governmental request.
- To protect rights, property, and others: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of Cognitive Concierge, third parties, or the public at large. For example, if we have a good faith belief that there is an imminent danger of death or serious physical injury, we may disclose information related to the emergency without delay.
- With your consent: We may share and disclose information with your consent or at your direction. For example, we may share your information with third parties when you authorize us to do so.
- Aggregated or de-identified information: We may share information that has been aggregated or de-identified, so that it can no longer reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Services, or share a hashed version of your email address to facilitate customized ad campaigns on other platforms.
- Published support requests: If you send us a request for assistance (for example, via a support email or one of our other feedback mechanisms), we reserve the right to publish that request in order to clarify or respond to your request, or to help us support other users.
We have a long-standing policy that we do not sell our users’ data. We aren’t a data broker, we don’t sell your personal information to data brokers, and we don’t sell your information to other companies that want to spam you with marketing emails.
Information Shared Publicly
Information that you choose to make public is — you guessed it — disclosed publicly. That means information like comments or “likes” that you post on our Services. Please keep all of this in mind when deciding what you would like to share publicly.
How Long We Keep Information
We generally discard information about you when it’s no longer needed for the purposes for which we collect and use it — described in the section above on How and Why We Use Information — and we’re not legally required to keep it.
While no online service is 100% secure, we work hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so.
You have several choices available when it comes to information about you:
- Limit the information that you provide: If you have an account with us, you can choose not to provide the optional account information, profile information, and transaction and billing information. Please keep in mind that if you do not provide this information, certain features of our Service will not be accessible.
- Limit access to information on your mobile device: Your mobile device operating system should provide you with the option to discontinue our ability to collect stored information or location information via our mobile apps. If you choose to limit this, you may not be able to use certain features, like geotagging for photographs.
- Opt out of marketing communications: You may opt out of receiving promotional communications from us. Just follow the instructions in those communications or let us know. If you opt out of promotional communications, we may still send you other communications, like those about your account and legal notices.
- Set your browser to reject cookies: At this time, Cognitive Concierge does not respond to “do not track” signals across all of our Services. However, you can usually choose to set your browser to remove or reject browser cookies before using the Cognitive Concierge website, with the drawback that certain features of the Cognitive Concierge website may not function properly without the aid of cookies.
- Close your account: While we’d be very sad to see you go, you can close your account if you no longer want to use our Services. Please keep in mind that we may continue to retain your information after closing your account, as described in How Long We Keep Information above — for example, when that information is reasonably needed to comply with (or demonstrate our compliance with) legal obligations such as law enforcement requests, or reasonably needed for our legitimate business interests.
If you are located in certain parts of the world, including California and countries that fall under the scope of the European General Data Protection Regulation (aka the “GDPR”), you may have certain rights regarding your personal information, like the right to request access to or deletion of your data.
European General Data Protection Regulation (GDPR)
If you are located in a country that falls under the scope of the GDPR, data protection laws give you certain rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:
- Request access to your personal data;
- Request correction or deletion of your personal data;
- Object to our use and processing of your personal data;
- Request that we limit our use and processing of your personal data; and
- Request portability of your personal data.
You also have the right to make a complaint to a government supervisory authority.
California Consumer Privacy Act (CCPA)
The California Consumer Privacy Act (“CCPA”) requires certain websites to provide California residents with some additional information about the categories of personal information that is collected and shared, where the website get that personal information, and how and why the website uses that personal information. While Cognitive Concierge currently does not exceed any of the current CCPA thresholds and are thus not obligated to comply with the CCPA requirements, we do generally strive to satisfy the requirements of the CCPA as a matter of principle.
The CCPA requires websites to provide a list of the “categories” of personal information that is collected, as that term is defined in the law, so. In the last 12 months, Cognitive Concierge collected the following categories of personal information from California residents, depending on the Services used:
- Identifiers (like your name, contact information, and device and online identifiers);
- Commercial information (your billing information and purchase history, for example);
- Characteristics protected by law (for example, you might provide your gender as part of a research survey for us);
- Internet or other electronic network activity information (such as your usage of our Services);
- Geolocation data (such as your location based on your IP address);
- Audio, electronic, visual or similar information (such as your profile picture, if you uploaded one);
- Professional or employment-related information (for example, your company and title, or information you provide in a job application); and
- Inferences we make (such as likelihood of retention or attrition).
You can find more information about what we collect and sources of that information in the Information We Collect section above.
We collect personal information for the business and commercial purposes described in the How and Why We Use Information section. And we share this information with the categories of third parties described in the Sharing Information section.
If you are a California resident, you have additional rights under the CCPA, subject to any exemptions provided by the law, including the right to:
- Request to know the categories of personal information we collect, the categories of business or commercial purpose for collecting and using it, the categories of sources from which the information came, the categories of third parties we share it with, and the specific pieces of information we collect about you;
- Request deletion of personal information we collect or maintain;
- Opt out of any sale of personal information; and
- Not receive discriminatory treatment for exercising your rights under the CCPA.
The CCPA & Personalized Advertising
The personal information we share includes online identifiers; internet or other network or device activity (such as cookie information, other device identifiers, and IP address); and geolocation data (approximate location information from your IP address). These disclosures may be considered a “sale” of information under the CCPA. We do not sell (or share) information through our ads program that identifies you personally, like your name or contact information. We don’t knowingly sell personal information of those under 16.
Contacting Us About These Rights
You can usually access, correct, or delete your personal data using your account settings and tools that we offer, but if you aren’t able to or you’d like to contact us about one of the other rights, scroll down to the Contact Us section at the bottom of our website to find out how to reach us.
When you contact us about one of your rights under this section, we’ll need to verify that you are the right person before we disclose or delete anything. For example, if you are a user, we will need you to contact us from the email address associated with your account. You can also designate an authorized agent to make a request on your behalf by giving us written authorization. We may still require you to verify your identity with us.
Other Things You Should Know
- In the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield; or
- In the case of entities based in other countries outside the EEA, entering into European Commission approved standard contractual arrangements with them.
You can ask us for more information about the steps we take to protect your personal information when transferring it from the EU.
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