Cognisess Legal

Privacy Policy

INTRODUCTION

This privacy policy explains what personal data Cognisess collects from you, through our interactions with you and through our products, and how we use that data. This applies to Cognisess’s interactions with you through the Cognisess platform and its products.

Cognisess, having its registered office at 10 Argyle Street, Bath, BA2 4BQ, aims to democratize human capital and empower every person and every organization to understand and enhance their talent and potential. We are doing this by building an intelligent platform, reinventing people-focused and business processes. In all of this, we will uphold the timeless value of privacy and preserve the ability for you to control your data.

In this policy, we cover what data is collected, how it’s collected, and how it’s used, so that you have the right information to make informed decisions across our products and services. By using our Services, you consent to our use of your data under this Privacy Policy.

Here are the main points of this Privacy Policy in summary:
• You provide this data voluntarily – it is entirely your choice.
• We use the data to create your digital profile, match you to a profiler, and handle job applications.
• We give you the option to show yourself to others via recorded videos.
• We don’t trade or sell data – it is and will always remain yours.
• Your profile is yours for life – you are in control of what we know about you, every step of the way.
• You can choose to be anonymous and only share what you want with others.

INFORMATION WE COLLECT

Cognisess collects data to operate effectively and provide you the best experiences with our products. You provide some of this data directly, such as when you create a Cognisess account, upload a document, purchase a product or service, record a video profile or contact us for support. We get some of it by recording how you interact with our products, for example, using technologies like cookies, and receiving error reports or usage data from your device.

You have choices about the data we collect. When you are asked to provide personal data, you may decline. But if you choose not to provide data that is necessary to provide a product or feature, you may not be able to use that product or feature. Broadly, the data we collect can include the following categories:

As a candidate or employee:
• Name and contact data: We may collect your first and last name, email address, postal address, phone number and other similar contact data.
• Credentials: We collect passwords, password hints and similar security information used for authentication and account access.
• Demographic data: We collect data about you such as your age, gender, country and preferred language.
• Employment details: We collect data about current and previous employment.
• Education data: We collect your education data such as university, year of study as well as grade you achieved.
• Job Application data: As part of your job application, we may ask you specific questions and your preferred choices along with your responses.
• Sensitive data: We collect sensitive personal data which includes details of your health condition. This is for the purposes of fairer assessment. Providing this information is entirely optional and it will not affect the scores or how your profile is presented.
• Biographical information: We collect data about you, your interests and hobbies, work experience, education and other elements to help build a digital profile.
• Video information: We may collect video data which includes your responses to specific questions.
• Assessment scores: We collect the scores of the assessments that you play on our platform.
• Other: We collect data when you fill out a form, respond to a survey, or submit a resume to apply for jobs.
• Device and Usage data: We collect data about your device and how you and your device interact with Cognisess products.
• Performance data: We collect data about the performance of the products and any problems you experience in Cognisess products. This data helps us to diagnose problems in the products you use, and to improve our products and provide solutions.
• Team relationships: We collect data about your teams and roles if you use a Cognisess product to manage candidates, employees or contacts.

As an Organisation:
• Organisation details: We collect data such as organisation name, address and further contact details.
• Job vacancies: We may collect the data about job opportunities in your organisation.
• Payment data: We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument.
• Feedback and Reviews: We also collect information you provide to us and the content of messages you send to us, such as feedback and product reviews you write, or questions and information you provide for customer support.

COGNISESS PROFILE

To create an account, you provide data including your name, email address and/or mobile number, and a password. When you create a personal Cognisess account, you will be asked for certain personal data and we will assign a unique ID number to identify your account and associated information.

You have choices about the information on your profile, such as your education, work experience, skills, photo and city or area. Some professionals may choose to complete the baseline assessments. Profile information helps you to get more from our Services, including helping recruiters and business opportunities find you. It’s your choice whether to include sensitive information on your profile. Please do not add any personal data to your profile that you would not want to be available to your employer.

SIGNING IN

When you sign into your Cognisess account, we create a record of your sign-in, which includes the date and time, information about the product you signed into, your sign-in name, the unique number assigned to your account, a unique identifier assigned to your device, your IP address and your operating system and browser version.

Other information from Service use
In addition to the information you provide, Cognisess may also collect data during your visit to a Cognisess website through Automated Tools, which include cookies, embedded Web links, and other commonly used information-gathering tools. These tools collect certain standard information that your browser sends to our website such as your browser type and language, access times, and the address of the website from which you arrived at an Cognisess website. Using these tools, Cognisess is also able to confirm receipt of e-mails that the recipient consented to receive and can understand other information such as pages visited on the Cognisess site and certain other aggregate data that is not related to a particular individual.

IP Addresses
We use IP addresses to establish the country from which a user is using our websites and services to administer our website, and to gather demographic information. We may also use IP addresses or other information, you have shared on this website or at any earlier occasion, to determine which pages on our sites you visit, and which topics may be of interest to you, so we can provide you with information about relevant products and services.

Cognisess is, in particular, currently using the following Automated Tools for the purposes set out below.
a. Google Analytics
Some websites which refer to this privacy policy use Google Analytics. Google Analytics uses cookies, which are text files placed on your computer to help the website analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers. Google will use this information for the purpose of evaluating your use of the website, compiling reports on site activity for site operators and providing other services relating to site activity and internet usage.

b. Embedded Web Links
Emails from Cognisess often use links designed to lead you to a relevant area on the Web, after redirection through Cognisess’s servers. This redirection method allows Cognisess to change the destination URL of these links, if necessary, and to determine the effectiveness. In emails, such links may also permit Cognisess to decide if you have clicked on a link in the email, and the data about this communication may be connected to your personal identity. If you do not want Cognisess to collect information about the links you clicked, you can simply choose not to click on the links in an e-mail that Cognisess sends you.

c. Cookies
Cookies are identifiers that can be sent from a site via your browser to be placed on your computer’s hard drive. Cognisess uses cookies to save you having to re-enter your password and to complete registration forms repeatedly. By gathering the information about your interaction with website through cookies we can provide you a better user experience. For more information, please refer our Cookie policy.

HOW WE COLLECT YOUR DATA

To serve you better and understand your needs and interests, Cognisess collects, exports, and uses Personal Data with adequate notice and, where legally required, consent, along with required filings with data protection authorities, when applicable. The following are the main ways in which we collect the data:

Information you provide to us directly
As a job seeker or candidate, by using our products you are consent to the collection and use of your Personal Data as described. If you do not agree with the terms & conditions, please do not use this website & services.

As we are required by applicable law, we may also seek your explicit consent to process certain Personal Data collected on our services by you. Kindly note that any consent will be entirely voluntarily. In case you do not grant the requested consent to the processing of your Personal Data or later inform Cognisess that you do not want Cognisess to further process your Personal Data (Data Retention), the further use of certain offerings or services of Cognisess may be either not possible or limited in scope.

Information your employer provides to us
As an employee, we may collect your data from your employer where a Data processing agreement will be in place in order to process the personal data on behalf of your employer. By signing up on our platform and services, you are giving consent to us for processing and we will be able to provide the right services in accordance with your requirements. In the case you do not want to use our platform or want to discontinue in our products, we are committed to destruct the personal data by acceptable means. Otherwise, you are asked to carefully read the privacy policy as well as terms & condition and tick a consent box if you agree.

Information we collect automatically
When you use our website or products, we automatically collect your data such as IP address and device details through automated tools. We also collect the data about your usage in our platform and services which includes what pages you looked at and what hyperlinks you clicked on. This information provides us useful insights to better understand of how you’re using our platform and services. Thereby we can continually improve our service and serve you better experience in our platform.

We collect some of these data through cookies and other similar technologies. If you want to know more about what kind of cookies we use, why, and how you can control them, please take a look at our cookie policy.

Information we collect from third parties
Most of the times, we collect the data directly from you. Occasionally, we might collect the data from other source such as from our trusted research partners. We use this information to supplement the personal data we already hold about you, in order to better inform, customise and improve our services, and to validate the personal data you provide.

Where we collect personal data, we’ll only process it:
• to perform a contract with you, or
• where we have legitimate interests to process the personal data and they’re not overridden by your rights, or
• in accordance with a legal obligation, or • where we have your consent.

If you don’t want us to collect your personal data, we may be unable to provide you with all our services, and some functions and features on our websites may not be available to you.

WHY ARE WE COLLECTING THIS DATA?

The reasons why people use our platform differ, but below are the most common use cases, from our perspective:
• The one such purpose for processing your personal data is to manage your application and to match your data with the requirements of available jobs via the Cognisess Platform. We want to give you the opportunity to share scores on assessments with employers to show what makes you good at what you do, and why you would be a good candidate to consider. Also, this can help you find a career or job that you might not have considered before.
• For employees and individuals, we are providing a platform for personal development and a way for organisations to build better and more balanced teams, based on existing skills.
• We collect video data to gain a better understanding of how you present yourself and respond to particular questions that employers might want to ask candidates or employees. Cognisess has developed algorithms to analyse videos including human expression and language based on universal scientific paradigms. To remove any bias Cognisess never uses age, gender, ethnicity or culture in its algorithms. Organisations are able to view your completed videos if you consent as part of your job application or employee appraisal.
• We collect your age, gender and similar information and this is for global research and norming purposes only. All biographical data is non-mandatory. In no way does this information impact on your application and cannot be part of a profiler. Equality is very important to us.

As an Organisations:
• To provide marketing or promotional activities on the www.cognisess.com or other Cognisess websites. Personal Data such as name and email address may be collected to administer those programs.
• To conduct questionnaires and surveys in order to provide better products and services to our customers and end users. Your completion of any questionnaires is voluntary.
• To support recruitment inquiries.
• To prepare anonymized data regarding the use of Cognisess websites and offerings. Cognisess will use such anonymized data only for the improvement of such websites and offerings.
• To process your orders and deliver the services as well as to provide access to our services that you have ordered.
• To keep you up to date on the latest platform features, platform service updates and other information regarding Cognisess’s platform and services.
• To meet contractual obligations.
• To comply with applicable regulatory requirements, in particular resulting from export laws. Cognisess and its products, technologies and services are subject to the export laws of various countries, including without limitation, to those of the European Union and its member states, and the United States of America.
• Cognisess is required to take measures to prevent entities, organizations and parties listed in government issued sanctioned party lists from accessing certain products, technologies and services through Cognisess’s websites or other channels controlled by Cognisess. You therefore understand and agree that Cognisess may (i) automatically check any user registration data and other information you provide about your identity against applicable sanctioned party lists; (ii) regularly repeat such checks whenever a sanctioned party list is updated or when you update your information; (iii) block your access to Cognisess’s services and systems in case of a potential match; and (iv) in case of a potential match contact you in order to confirm your identity.

WHO IS HANDLING YOUR DATA?

We, Cognisess Ltd., having our registered office at 10 Argyle St, Bath BA2 4BQ, UK, are legally considered as data processor for the personal data contained in your job application and consider as data controller for the personal data in your Cognisess account. We store our data on Cognisess servers that are continuously monitored to make sure your data is safe, protected and served in the right location.

Your data always stays yours, and you can always access and modify it. Any personal information that you provide us with may be transferred to other Cognisess entities in other European jurisdictions. We never sell, rent, trade or otherwise disclose the personal information you provide to anyone outside of Cognisess without your expressed permission. If used for a job application or as an employee, please be aware that the employer, recruiter or HR professionals handling the accounts to process applications and staff profiles may be able to see some of the information that you provide. Your data is encrypted with industry standard encryption technology whilst stored.Cognisess

WHERE WE STORE AND PROCESS PERSONAL DATA

Keeping your personal data securely is very important to us. Therefore, personal data collected by Cognisess may be stored and processed with the high standards required under data protection legislation. Cognisess hosts your data using Microsoft Azure and store certain information in Drobox with industrial standard protection in place. We take steps to ensure that the data we collect under this privacy policy is processed as stated by this policy and the requirements of applicable law wherever the data is located.

HOW WE SHARE YOUR INFORMATION

Any personal data and information that you give to us is confidential. We may disclose your personal information to another entity only in certain following circumstances:
• We may share such data with service vendors, business partners, authorized thirdparty agents, contractors to provide a requested service or transaction, including processing credit card transactions, hosting websites, providing customer support, and providing you with information on products and services.
• We may share your name and email address with our marketing partners, only if you opted in for our newsletters and marketing materials.
• We only provide these third parties with the minimum amount of Personal Data necessary to provide the services on our behalf, and the third parties are (where legally required) bound by appropriate data processing agreements and/or comprehensive confidentiality undertakings and therefore not permitted to use your Personal Data except for the limited purpose of completing the requested service or transaction.
• We may respond to subpoenas, court orders, or legal process by disclosing your Personal Data and other related information, if necessary. We also may choose to establish or exercise our legal rights or defend against legal claims.
• Circumstances may arise where, whether for strategic or other business reasons, Cognisess decides to sell, buy, merge or otherwise reorganize businesses in some countries. Such a transaction may involve, in accordance with applicable law, the disclosure of Personal Data to prospective or actual purchasers, or the receipt of it from sellers. It is Cognisess’s practice to seek appropriate protection for information in these types of transactions.
• We may collect and share Personal Data and any other additional information available to us in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Cognisess’s Terms of Use, or as otherwise required by law.
• Cognisess may use the information in connection with processing your inquiries and activities, in order to provide services to you, to help improve our products and services to keep you up to date about the latest product announcements, newsletters, platform enhancements, for processing as well as storage and for all other purposes set out in the section “WHY ARE WE COLLECTING THIS DATA?” above.
• While visiting Cognisess’s website you may be directed to content or functionality that is hosted by a third-party supplier. When information is collected on behalf of Cognisess exclusively, the Cognisess’s privacy statement will be referenced on the website and will govern how information is used. For other, non-Cognisess sites, the site’s owner’s privacy policy will be referenced. It is Cognisess’s practice to require such suppliers and business partners to handle information in a manner consistent with Cognisess’s privacy policy.
• Finally, we do not sell or rent your Personal Data to third parties for marketing purposes unless you have granted us permission to do so.

YOUR CHOICES & OBLIGATIONS

As far as we are concerned, the data is yours and we want to make sure you are happy with what is on your profile. You have the right to correct or modify your data at any time. You also have the right to withdraw your application and/or profile at any time by contacting the employer, recruiting organisation or Cognisess directly at support@cognisess.com. Your data will then be deleted.

Data Retention & Account Closure
Cognisess will not retain your Personal Data longer than is necessary to fulfil the purposes for which it was collected or as required by applicable laws or regulations. In particular, and if no such contradicting statutory obligation exists, Cognisess will delete your Personal Data once you inform Cognisess or by withdrawing your consent with Cognisess that you do not want Cognisess to further process your Personal Data.

Please direct any such request to support@cognisess.com. Kindly note that in this case the use of certain services or offerings may either be limited or not possible any longer. In case there is a contradicting statutory obligation for Cognisess to retain your Personal Data, Cognisess will block it against further processing and then delete the relevant Personal Data when the requirement to retain it has ceased.

We refresh your consent over the period of time and also update you about the changes in this policy. We therefore wanted you to review the changes and seek your consent with updated changes in order to effectively use our platform and services.

Rights to Access and Control Your Personal Data
Cognisess adheres to applicable data protection law (UK data protection law and General Data Protection Regulation (GDPR)).As the processing of personal data is based on your consent, the following rights are applicate to you:

• You have a right to delete your personal data from us by withdrawing consent at any time.
• You have a right to access to and rectification of your personal data
• You have a right to object to the processing of your personal data
• You have a right to lodge a complaint with a data protection authority
• You have a right to data portability which allows you to obtain and reuse your personal data for your own purposes across different services.
• You have the right to restrict the further processing of your personal data.
• You have the right in relation with the profiling we provide.
• As applicable under French law, you can also send us specific instructions regarding the use of your personal data after your death.

When we process personal data about you, we do so with your consent and/or as necessary to provide the products you use, operate our business, meet our contractual and legal obligations, protect the security of our platform and services as well as our customers.

Cognisess needs your help in keeping the Personal Data you have shared with us accurate and up to date. If you are a registered user, you may make these updates yourself online via app.cognisess.com. You may also make these updates or other changes by sending an email to support@cognisess.com. To exercise your rights, you can always contact us by sending an email to dataprotection@cognisess.com.

INTERNATIONAL DATA TRANSFERS

When we share your personal data, it may be transferred to, and processed in countries other than you reside. For instance, our data hosting’s servers are mainly located within European Economic Area. Countries outside the EEA may under different data protection law, which you are not used to. When we share your personal data to a third party reside in another country, we ensure that your personal data is protected by keeping safeguards in place.

This means that the personal data of individuals in European Economic Area (EEA) may be transferred outside the EEA. In that case, we only transfer to countries that have been identified as providing acceptable protection to EEA data or to a third party where we have approved transfer mechanisms in place to protect your personal data. We ensure the data is protected by third parties by having European Commission’s Standard Contractual Clauses in Data Processing Agreement or by confirming the entity is Privacy Shield certified. For more information, please contact us by sending an email to dataprotection@cognisess.com.

OTHER IMPORTANT INFORMATION

Security of Your Personal Data
Cognisess is committed to protecting the Personal Data you share with us. Cognisess uses a combination of industry-standard security technologies, procedures, and organizational measures to help protect your Personal Data from unauthorized access, use or disclosure. Cognisess supports online security using secure server technology because we want your data to be safe. There are state-of-the-art security arrangements and facilities on Cognisess sites to prevent security issues. We bind our employees and data processors to observe your privacy and confidentiality rights.

We monitor for and try to prevent security breaches. We implement security safeguards designed to protect your data, such as HTTPS. We regularly monitor our systems for possible vulnerabilities and attacks. For example, we store the personal data you provide on computer systems that have limited access and are in controlled facilities. When we transmit highly confidential data (such as a credit card number or password) over the Internet, we protect it through the use of encryption.

Links to Other Sites
This website may contain links to foreign (i.e. non Cognisess group of companies) sites. Cognisess is not responsible for the privacy practices or the content of other websites outside the Cognisess Group of companies. Therefore, we recommend that you carefully read the privacy statements of such foreign sites.

Communication
We communicate with you by phone or via email to resolve customer complaints or investigate suspicious transactions. We may use your email address to confirm your opening of an account, to send you notice of transactions, to send you information about changes to our products and services, and to send notices and other disclosures as required by law.

For marketing purposes, we communicate with subscribers who consent our services for marketing purposes on a regular basis via email and subscribers can opt out at any time from these communications.

If you choose to give us your e-mail address, we will communicate with you via e-mail. We do not share your e-mail address with others outside the Cognisess group of companies unless this is required for the business relationship between you and Cognisess or if you register for third party services. You can choose not to receive any more e-mails at any time. However, such choice will not affect the sending of emails that are strictly required to perform the business relationship between you and Cognisess.

Russia-Specific Provisions
The below applies to users residing in the Russian Federation: The services here under are not intended for use by the citizens of the Russian Federation, who reside in Russia. If you are a Russian citizen residing in Russia, you are hereby notified, that any Personal Data that you input into the services will be solely at your own risk and responsibility, you consent that Cognisess may accumulate your Personal Data and will process this data in the EU and in other countries and that you will not hold Cognisess accountable for any potential non-observance of the Russian Federation legislation.

Changes to This Privacy Policy
We will update this privacy policy when necessary to reflect customer feedback and changes in our products. When we post changes to this policy, we will revise the “last updated” date at the bottom of the document. We encourage you to periodically review this privacy policy to learn how Cognisess is protecting your information.

Contact
For more information about this document or any other matter relating to ‘Terms & Conditions’ or ‘Privacy Policy’ then contact the Data Protection Officer at dataprotection@cognisess.com or visit www.cognisess.com.

All rights reserved. © Cognisess 2018.
Published by Cognisess, May 16 2018.

 

Contact
For more information about this document or any other matter relating to ‘Terms & Conditions’ or ‘Privacy Policy’ then contact the Data Protection Officer at dataprotection@cognisess.com or visit www.cognisess.com.

All rights reserved. © Cognisess 2018.
Published by Cognisess, May 16 2018.