Privacy Policy

Last Updated: January 2021

This website ("Site") is owned and operated by Cogention LLC. ("We," "we," “us,” or "Cogention"). This privacy policy ("Policy") describes how we may use and disclose personally identifiable information that we may collect about you (“you” or “your”) through the Site or through our relationship with you ("Personal Information"). This Site is hosted in the United States and is generally intended only for users in the United States. 

With respect to Site visitors, when you use or register with the Site, we may ask for certain Personal Information. We may also obtain Personal Information directly from you or your browsing activities on the Site. For such activities, we collect the following categories of Personal Information from you:

• Internet activity, such as your browsing activity on the Site, IP address, cookies, and geolocation data 
• Professional information such as email address

Subject to applicable law, by providing your mobile phone number to us, you opt in and consent to receive text messages from us, which includes but is not limited to text messages sent through an automatic telephone dialing system. Consent to receive marketing text messages is not required. If you do not wish to receive marketing text messages, do not provide us with your mobile phone number.

We specify below the business and commercial purposes for which we use Personal Information. We use Personal Information to track your preferences, learn about what professional interests you have, to provide you with requested information or services. We may from time to time use your Personal Information within the categories of identifiers and internet or other electronic activity information to send you automated email messages, text messages (message and data rates may apply), or marketing materials regarding our services. We may also use Personal Information such as geolocation data for our business purposes, such as data analysis, audits, and improving our services. 

We may also from time to time use your Personal Information to send you automated email messages or marketing materials regarding our services. These email messages may contain web beacons and other features that help us make sure that you received and were able to open the message. You may opt out of receiving such marketing email messages at any time by sending a message with "unsubscribe" in the subject line to jfink@cogention.com.

In addition to the above purposes, we use your information as described in the section below titled "Disclosures of Personal Information for Business and Commercial Purposes".

For business and commercial purposes, we may disclose to third parties the following categories of Personal Information to assist us with a variety of business and commercial functions: 

• Identifiers such as your name and email address
• Characteristics of protected classifications under applicable law such as gender, ethnicity, or whether you are a veteran
• Internet or other electronic activity information such as network activity information, browsing history on the Site, search history on the Site, and your interaction with an advertisement
• Geolocation data

Such functions may include hosting our Web servers, analyzing data, counting ad impressions to unique visitors, detecting security incidents, protecting against malicious, deceptive, fraudulent, and illegal activity, providing legal, accounting and marketing services, customer relationship management services, processing payments, and providing other support services.

We may disclose such Personal Information to the following categories of third parties:

• Service Providers. We may share Personal Information with our third-party service providers who perform business functions and services on our behalf  and other third parties who host our Web servers, analyze data, and provide legal, accounting, marketing, and support services.
• As required or appropriate by law. We may disclose Personal Information to regulatory authorities, government authorities or courts to comply with applicable laws, the service of legal process, or if we reasonably believe that such action is necessary to (a) comply with the law requiring such disclosure; (b) protect the rights or property of Cogention or its affiliated companies; (c) prevent a crime or protect national security; or (d) protect the personal safety of the users or the public. 
• Business transfers. We also may disclose or transfer information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

“Other Information” is any information that generally does not reveal your specific identity or does not directly relate to an identifiable individual. We may collect Other Information in a variety of ways, including:

• Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, and Internet browser type and version. We use this information to ensure that the Site functions properly.
• Using cookies: Cookies are pieces of information placed on your computer by a website server and stored on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Site, pages visited, registrations, submissions, demographics, information requests, language preferences, and other traffic data. Cookies on this track your online activities and may link that information with Personal Information you have provided us through online forms. We use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience. We also gather statistical information about use of the Site to enhance its functionality, understand how it is used and assist us with resolving questions about it. We may also use cookies and other technologies in online advertising campaigns to track responses to our ads.

If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies, or be given the choice of declining or accepting a particular cookie (or cookies) from a particular site. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Site. The Help section of the toolbar on most browsers will tell you how to set your browser to prevent accepting new cookies, how to have the browser notify you when you receive a new cookie or how to disable cookies altogether.

• Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of Site users and email recipients, market our services to you, measure the success of our marketing campaigns and compile statistics about Site usage and response rates.
• Analytics: We use third-party analytics providers such as Google Analytics  on the Site. Google Analytics uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. Google Analytics may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and opt out by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout. 
• IP Address: Your IP Address is a number that is automatically assigned to your computer by your Internet Service Provider. An IP Address may be identified and logged automatically in our server log files whenever a user accesses the Site, along with the time of the visit and the pages visited. We use IP Addresses for purposes such as calculating usage levels, diagnosing server problems, and administering the Site. We may also derive your approximate location from your IP Address.

We may use third-party advertising companies to serve ads regarding our services when you access and use other websites, based on information relating to your use of the Site. To do so, these companies may place or recognize a unique cookie on your browser (including through use of pixel tags). By utilizing the Site, you consent to the use of cookie or other tracking technologies to serve you retargeted advertising.

This Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Site links.

We use reasonable organizational, technical and administrative measures designed to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section below.

If we change this Policy we will post any updates here for your review. We will also take other steps as necessary depending on the nature of the changes, including obtaining your consent where required by local data protection laws, or providing you with the opportunity to delete your Personal Information.

Subject to certain exceptions, as a California resident, you have the right to: (i) access your Personal Information; and (ii) obtain deletion of your Personal Information. To the extent permitted by applicable law, we may be required to retain some of your Personal Information, and certain Personal Information is strictly necessary in order for us to fulfill the purposes described in this Policy.

• Exercising other California consumer rights. Should you wish to exercise the rights as detailed above, you may: 
  • contact us by email at jfink@cogention.com and/or postal mail below
• Verification. In order to verify a request from you exercising your rights, you will need to submit a form referenced in the “Exercising other California consumer rights section” above providing (i) your legal first and last name, (ii) email address you use to correspond with Cogention, (iii) describe your relationship with Cogention, and (iv) provide the state you currently reside in. After you submit the form, Cogention will send you a response email to your email.

Note you will not receive discriminatory treatment from us for exercising your rights.

Cogention utilizes the Standard Contractual Clauses for data transfers from data controllers in the European Union to processors and controllers established outside the European Union or the European Economic Area, where appropriate.

Please contact us at jfink@cogention.com if you have any questions, wish to exercise your rights of access, or seek other assistance related to our participation in the Frameworks as described above.