CogX App - Privacy Policy

Privacy policy version: June 2021

The CogX App (the app) is provided by CogX Limited, a company registered in England under company number 09804338 with its registered office at 20 Air Street, London, United Kingdom, W1B 5AN trading as CogX (we, our or us). We are the controller of personal data obtained via the app, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data).

It also explains your rights in relation to your personal data and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use and sharing of your personal data is regulated by law, including under the General Data Protection Regulation (GDPR), the UK Data Protection Act 2018 (DPA) and the UK General Data Protection Regulation (UK GDPR).

If you are aged under 18 you must not use the app as it is not designed for you. We do not intend to collect the personal data of anyone under 18. If you are aware that any personal data of anyone under 18 has been shared with the app please let us know so that we can delete that data.

This privacy policy is divided into the following sections:

• What this policy applies to
• Personal data we collect about you
• Location services/data
• Use of the camera on your device for augmented reality
• How your personal data is collected
• How and why we use your personal data
• Marketing
• Who we share your personal data with
• How long your personal data will be kept
• Transferring your personal data out of the UK
• Your rights
• Keeping your personal data secure
• How to complain
• Changes to this privacy policy
• How to contact us
• Do you need extra help?

What this policy applies to

This privacy policy relates to your use of the app only.
The app may link to other individuals, businesses, apps, websites or services owned and operated by us or by certain trusted third parties to help create valuable professional connections, access relevant content and make additional products, information and services available to you). These other apps, websites or services may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other apps, websites or services, please consult their privacy policies as appropriate.

Personal data we collect about you

The personal data we collect about you depends on the particular activities carried out through the app. We will collect and use the following personal data about you:

Category of data Identity and account data you input into the app
Registration is mandatory in order to use the app
In more detail — your name, address and contact information, including email address and telephone number, social media links, social media handles, job title, type of job, company/organisation details
— your profile image
— topics you are interested in
— your account details, such as username and password
— details of how you heard about the app
Category of data Data collected when you use specific functions in the app In more detail — data you store online with us using the app (while such data may not always be personal data as defined at law in all cases we will assume it is and treat it in accordance with this policy as if it were)

— data regarding your activities and interactions on the app, including media and content that you view, searches you conduct, sessions that you book into or attend, questions you ask, polls you take part in, pages you visit, products and companies that you express interest in, other users and partners you interact with and meet with, meetings that you request, invitations and connections received, sent, accepted or rejected
Category of data Data collected when you permit the collection of location data In more detail — details of your location with a high degree of precision, for the purposes of recommending relevant connections and content linked to your country or city, see the section ‘Location services/data’ below Category of data Other data the app collects automatically when you use it In more detail — your activities on, and use of, the app which reveal your preferences, interests or manner of use of the app and the times of use

— number of connections and followers you have in the app, list of media files published by or featuring you

— IP address, device type, IMEA numbers, MAC address of networks, other unique device identification, device operating system, browser type, mobile network information, app version number, storage usage, data usage, time zone settings


If you do not provide personal data we ask for where it is indicated to be ‘required’ at the point of collection, it may prevent us from providing services to you.

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.

Location services/data

The app will request your consent to use location services to precisely identify your location each session (i.e. each time the app is opened or has been placed in the background). We require access to that data in order to recommend you content and connections that may be more relevant to you due to your location.

If you do not provide your consent you may use the app but that will mean the content and connections suggested to you may be less relevant. To withdraw your consent at any time please contact us as set out below.

The location services in the app will not operate unless location services/data are generally enabled on your device. You may disable such functionality at any time by changing your device settings. When you allow your device to use location services/data, data will also be collected by the organisations providing the device operating system in accordance with their privacy policies.

Use of the camera and microphone on your device

Permission will be requested to use the camera and microphone on your device in order to enable certain features in the app, for example uploading your profile picture or recording your own content.

You may disable the app’s access to the camera and microphone on your device at any time by changing your device settings although that will mean that certain video and audio features on the app are no longer available.

How your personal data is collected

We collect personal data from you directly when you input it into the app or indirectly, such as your activity while using the app.

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason, eg:

• where you have given consent
• to comply with our legal and regulatory obligations
• for the performance of a contract with you or to take steps at your request before entering into a contract, or for our legitimate interests or those of a third party

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

The table below explains what we use your personal data for and why.

What we use your personal data for Create and manage your account with us Our reasons For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver an enjoyable and relevant service to you What we use your personal data for Providing access to the app, our services and the functionalities of the app to you, including:

To deliver services on the app, including audio/visual content, virtual events, networking, social interaction, recommendation of content, and other services

To provide management of invitations by our partners

To communicate to you any useful information regarding future events, services, and opportunities with relation to the app or CogX

To email you regarding abandoned checkout processes

Once you have registered for the app, to provide necessary information to you in connection with your attendance of events, sessions, networking sessions and other services we provide.

To invite you to register to any new apps, platforms or online services offered by us and our group companies CognitionX Limited and CogX Events Limited

To invite you to register to any new event organized by our partners, including partners exhibiting on the app

To measure the audience on the app and to measure use of and interest in specific features and content

To measure the performance of our social media campaigns and mobile campaigns

To facilitate interactions between other users of the app via communication channels within the app and via other 3rd-party communication channels as may be appropriate, including recommending you to connect with other users or recommending relevant content

To manage the experience of any events hosted by us
Our reasons — to perform our contract with you or to take steps at your request before entering into a contract

— for our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver an enjoyable and relevant service to you

In relation to the connection between you and third parties on the app we will use data based on your consent. Your Summary Profile information that you choose to upload (which comprises your name, company, job title, country but NOT your contact details) will be visible to other users if the app suggests you as a connection or if you consume the same content. Your email address will only be shared if you accept a connection request from another user

We will use data relating to your location only based on your consent as described in ‘Location services/data’ (above)
What we use your personal data for Conducting checks to identify you and verify your identity or otherwise to help prevent and detect fraud against you or us Our reasons For our legitimate interests or those of a third party, i.e. to minimise the risk of account or identity theft or fraud that could be damaging for you, a third party or us What we use your personal data for To enforce legal rights or defend or undertake legal proceedings Our reasons Depending on the circumstances

— to comply with our legal and regulatory obligations

— in other cases, for our legitimate interests or those of a third party, ie to protect our business, interests and rights or those of others
What we use your personal data for Communications with you not related to marketing, including about changes to our terms or policies or changes to the app or service or other important notices, or responding to your queries Our reasons Depending on the circumstances:

— to comply with our legal and regulatory obligations

— in other cases, for our legitimate interests or those of a third party, i.e. to provide the best service to you
What we use your personal data for Protect the security of systems and data Our reasons To comply with our legal and regulatory obligations

We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, ie to protect systems and data and to prevent and detect criminal activity that could be damaging for you or us
What we use your personal data for Operational reasons, such as improving efficiency, training and quality control or to provide support to you Our reasons For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver an enjoyable and relevant service to you What we use your personal data for Statistical analysis to help us manage our business, e.g. in relation to our commercial performance, customer base, product and service range or other efficiency measures Our reasons For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver an enjoyable and relevant service to you What we use your personal data for Updating and enhancing customer records Our reasons Depending on the circumstances:

— to perform our contract with you or to take steps at your request before entering into a contract

— to comply with our legal and regulatory obligations

— where neither of the above apply, for our legitimate interests or those of a third party, eg making sure that we can keep in touch with our users about relevant content or features
What we use your personal data for Disclosures and other activities necessary to comply with legal and regulatory obligations, e.g. to record and demonstrate evidence of your consent to our use of your personal data where relevant Our reasons To comply with our legal and regulatory obligations What we use your personal data for Marketing our services to existing and former customers Our reasons For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers
See ‘Marketing’ below for further information.
What we use your personal data for To share your personal data with members of our group and third parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency

In such cases information will be anonymised where possible and only shared where necessary
Our reasons Depending on the circumstances:

— to comply with our legal and regulatory obligations

— in other cases, for our legitimate interests or those of a third party, i.e. to protect, realise or grow the value in our business and assets


See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.

Marketing

We may use your personal data to send you updates (by email, text message, telephone or post) about our app, events, products and services, including offers, promotions or new services.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by:

contacting us at [email protected] or using the contact details below using the ‘unsubscribe’ link in emails

We will always treat your personal data with the utmost respect and never sell it to other organisations for marketing purposes without your consent.

For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below. Who we share your personal data with

We routinely share personal data with:

• service providers we use to help us run our business or provide the services or functionalities in the app, such as Amazon Web Services (AWS) and other agencies that host our servers, databases and systems that deliver the app’s functionalities, as well as services and analytics providers.

• relevant app stores where the app is available, such as Apple, Google and Amazon where you permit us to collect data as described in this privacy policy—for further information on how [these app stores protect personal data see their relevant privacy policies.

If you provide personal data to us through the app, certain personal data such as your name, company, job title, bio, contact details and profile image may be shared with our users (including business customers, publishers, partners and providers) in connection with the app, in the following ways:

• your Summary Profile information (which comprises your name, company, job title, country but NOT your contact details) will be visible to other users if the app suggests you as a connection or you consume the same content

• your Summary Profile information and details relating to your interaction with relevant content on the app will be visible to other users who publish such content on the app if you view their content or otherwise express interest in that user through the app

• if you choose to connect with a user through the app then you will share your email address with that user (who may choose to contact you by email outside of the app)

If a user contacts you outside of the app after you have accepted or initiated a connection through the app, we have no control over these communications and you should review that organisation's privacy policy in respect of opting out of receiving further communications or asking any questions regarding the processing of your personal data.

The Summary Profile information you make available through the app can be amended via your profile page. We only allow our group companies and service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.

We or the third parties mentioned above may occasionally also need to share your personal data with:

• professional advisors (such as lawyers, auditors and other advisors)—the recipient of the information will be bound by confidentiality obligations

• law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal and regulatory obligations

• other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

How long your personal data will be kept

Different retention periods apply for different types of personal data.

When you send us personal data via email, for example to ask a question or make a comment, or by filling out a form that emails us this information, we use it to respond to your requests. Personal data processed for these purposes will be retained as long as necessary to complete our response.

The personal data you have shared with us, and that enables us to contact you, will be kept until you communicate to us your intention to terminate your user account on the app. Your data may be retained for a further 30 days following such communication or where such retention is required for us to fulfil our legal obligations. The data that you have shared will be stored in accordance with legal obligations. Analytics data collected for the purposes of audience measurement, retargeting, measurement of the performance, will be kept for up to 5 years following your use of the app.

Following the end of the relevant retention period, we will delete or anonymise your personal data.

Transferring your personal data out of the UK

Countries outside the UK have differing data protection laws, some of which may provide lower levels of protection of privacy. It is sometimes necessary for us to share your personal data to countries outside the UK. In those cases we will comply with applicable UK laws designed to ensure the privacy of your personal data.

For example we will transfer your personal data from the UK to Ireland where our hosting and database service providers are located.

Under data protection laws, we can only transfer your personal data to a country outside the UK where:

the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR

there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you, or a specific exception applies under relevant data protection law

Where we transfer your personal data outside the UK we do so on the basis of an adequacy regulation or (where such is not available legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available here and includes countries in the EEA. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law.

Any changes to the destinations to which we send personal data or in the transfer mechanisms we use to transfer personal data internationally will be notified to you in accordance with the section on ‘Change to this privacy policy’ below.

Your rights

You generally have the following rights, which you can usually exercise free of charge:

Access to a copy of your personal data The right to be provided with a copy of your personal data Correction (also known as rectification) The right to require us to correct any mistakes in your personal data Erasure (also known as the right to be forgotten) The right to require us to delete your personal data—in certain situations Restriction of use The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data Data portability The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format or transmit that data to a third party—in certain situations To object to use The right to object:

— at any time to your personal data being used for direct marketing (including profiling)
— in certain other situations to our continued use of your personal data, e.g. where we use your personal data for our legitimate interests
Not to be subject to decisions without human involvement The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

We do not make any such decisions based on data collected by the app


If you would like to exercise any of those rights, please email, call or write to us—see below: ‘How to contact us’. When contacting us please:

• provide enough information to identify yourself (e.g. your full name, email address) and any additional identity information we may reasonably request from you (which may include proof of identity), and

• let us know which right(s) you want to exercise and the information to which your request relates

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to complain Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner (or the relevant data protection authority in your jurisdiction).

The Information Commissioner can be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.

Changes to this privacy policy

We may change this privacy policy from time to time. When we make significant changes we will take steps to inform you, for example via the app, a prominent notice or by other means, such as email. You are advised to review this privacy policy periodically for any changes. Changes to this privacy policy are effective when they are posted on this page.

How to contact us

You can contact us by post or email if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below:

Our contact details

CogX Limited, 20 Air Street, London, W1B 5AN

[email protected]


Do you need extra help?

If you would like this policy in another format (for example audio, large print) please contact us (see ‘How to contact us’ above).

CALIFORNIA SUPPLEMENTAL PRIVACY NOTICE

In addition to the rights described in our Privacy Policy above, California law grants California residents certain rights as set forth below:

Notice: You have a right to be provided with a notice at minimum of the categories of personal information collected and the purposes for which it is used at or before the points of collection.

Right to non-discrimination: The California Consumer Protection Act (“CCPA”), prohibits discrimination against California residents for exercising their rights under the CCPA, such as by denying or providing a different level or quality of goods or services, or charging different prices or imposing penalties on residents who exercise their CCPA rights, unless doing so is reasonably related to the value provided to the business by the residents’ data.

Submitting Requests

Requests to exercise your rights may be submitted by emailing us at [email protected]. Please be prepared to provide your first and last name and email address that matches information we currently have on file. Where we are unable to verify your identity based upon this information alone, we may require additional details. We will respond to verifiable requests received from California consumers as required by law.

California Shine the Light Law

Under California’s Shine the Light law, California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any, and as defined under the law) that we have shared with third parties during the preceding calendar year for their own direct marketing purposes. Such requests may be made once per calendar year by emailing us at [email protected]. In your request, you must include the statement “Shine the Light Request,” provide your first and last name, email address and residential address, and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency.