This Privacy Policy explains what information Cognology Pty Ltd and its related entities (“Cognology”) collect about you and why, what we do with that information, how we share it, and how we handle the content you place in our products and services.
This Privacy Policy applies to the information that we obtain through your use of “Cognology Services” via a “Device” or when you otherwise interact with Cognology.
“Cognology Services” include our:
but does not include:
Cognology products or services for which a separate privacy policy is provided.
Third party products. These are third party products or services that you may choose to integrate with Cognology product or services, such as third party eLearning resources for use with our Learning Management System (LMS). You should always review the policies of third party products and services to make sure you are comfortable with the ways in which they collect and use your information.
A “Device” is any computer used to access the Cognology Services, including without limitation a desktop, laptop, mobile phone, tablet, or other consumer electronic device.
Unless otherwise stated, our SaaS Products and our Downloadable Products are treated the same for the purposes of this document.
By registering for or using Cognology Services you consent to the collection, transfer, processing, storage, disclosure and other uses described in this Privacy Policy.
Add-On: a bundle of code, resources and configuration files that can be used with a Cognology product to add new functionality or to change the behavior of that product’s existing features.
Cognology Services: Cognology’s Websites, SaaS Products, and Downloadable Products.
Content: any information or data that you upload, submit, post, create, transmit, store or display in a Cognology Service.
Downloadable Products: Cognology’s downloadable software products, including Add-ons created by Cognology, that are installed by customers on any infrastructure of their choice. Downloadable Products do not include Add-Ons created by third parties, even when they are accessed through Cognology services or purchased from Cognology.
Information: all of the different forms of data, content, and information collected by us as described in this Privacy Policy.
Personal Information: information that may be used to readily identify or contact you as an individual person, such as: name, address, email address, or phone number. Personal Information does not include information that has been anonymized such that it does not allow for the ready identification of specific individuals.
SaaS Products: Cognology’s “OnDemand” or “Cloud” hosted solutions, as well as other Cognology hosted solutions that display a link to this Privacy Policy. For the avoidance of doubt, if a Cognology hosted solution displays a link to a different privacy policy, then that other privacy policy shall apply.
Websites: Cognology’s websites, including but not limited to cognology.com.au and any related websites, sub-domains and pages.
We may change this Privacy Policy from time to time. If we make any changes, we will notify you by revising the “Effective Starting” date at the top of this Privacy Policy and, in some cases, where appropriate we may provide you with additional notice (such as adding a statement to the login screen or sending you an email notification). We encourage you to review our Privacy Policy whenever you use Cognology Services to stay informed about our information practices and the ways you can help protect your privacy.
If you disagree with any changes to this Privacy Policy, you will need to stop using Cognology Services and discontinue your service(s).
We collect the following information:
Account and Profile Information: We collect information about you and your company as you create a user account, create or modify your profile, use, access, or interact with Cognology Services (including but not limited to when you upload, download, collaborate on or share Content). Information we collect includes but is not limited to your name, username, address, email address, phone number, profile photo, job title, feedback about yourself left by you or other people, feedback about other people left by you, qualifications and skills, performance goals, achievements, training and development, performance ratings or the requirements of your job role. You may provide this information directly when you enter it in Cognology Services, or in some cases another user (such as a system administrator) creating an account on your behalf may provide it. If you are providing information (including Personal Information) about someone else, you confirm that you have the authority to act for them and to consent to the collection and use of their Personal Information as described in this Privacy Policy.
Content: We collect and store Content that you create, input, submit, post, upload, transmit, store or display in the process of using our SaaS Products or Websites. Such Content includes any Personal Information or other sensitive information that you choose to include (“passively-collected Personal Information”).
Other submissions: We collect other data that you submit to our Websites or as you participate in any interactive features of the Cognology Services, participate in a survey, contest, promotion, activity or event, apply for a job, request customer support, communicate with us via third party social media sites or otherwise communicate with us. For example, information regarding a problem you are experiencing with a Cognology product could be submitted to our Support Services. Any information, including Personal Information, that you submit to our Websites could be visible to the public unless submitted to a secure area in the Website.
Web Logs: As is true with most websites and services delivered over the Internet, we gather certain information and store it in log files when you interact with our Websites and SaaS Products. This information includes internet protocol (IP) addresses as well as browser type, internet service provider, URLs of referring/exit pages, operating system, date/time stamp, information you search for, locale and language preferences, identification numbers associated with your Devices, your mobile carrier, and system configuration information. In the case of our SaaS Product, the URLs you accessed (and therefore included in our log files) include usernames as well as elements of Content as necessary for the SaaS Product to perform the requested operations. Occasionally, we connect Personal Information to information gathered in our log files as necessary to improve Cognology Services for individual customers.
Cookies and Other Tracking Technologies: We use various technologies to collect information, including cookies that we save to your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory. We use cookies to improve and customise Cognology Services and your experience; to allow you to access and use the Websites or SaaS Products without re-entering your username or password; and to count visits and understand which areas and features of the Websites and SaaS Products are most popular. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from websites you visit. If you do not accept cookies, however, you may not be able to use all aspects of our Websites or SaaS Products.
License Information from Downloadable Products: Our Downloadable Products communicate with Cognology servers for licensing purposes. Examples of information we collect for these purposes include the name and version of the Product and the server ID, SEN, and IP address of the customer instance.
Information from third party services: We also obtain information from third parties and combine that with information we collect through Cognology Services. For example, we may have access to certain information from a third party social media or authentication service if you log into Cognology Services through the service or otherwise provide us with access to information from the service. Any access that we may have to such information from a third party social or authentication service is in accordance with the authorization procedures determined by that service. By authorizing us to connect with a third party service, you authorize us to access and store your name, email address(es), current city, profile picture URL, and other information that the third party service makes available to us, and to use and disclose it in accordance with this Privacy Policy. You should check your privacy settings on these third party services to understand and change the information sent to us through these services.
General Uses. We use the information we collect about you (including Personal Information to the extent applicable) for a variety of purposes, including to:
Provide, operate, maintain, improve, and promote Cognology Services;
Enable you to access and use Cognology Services, including uploading, downloading, collaborating on and sharing Content;
Process and complete transactions, and send you related information, including purchase confirmations and invoices;
Communicate with you, including responding to your comments, questions, and requests; providing customer service and support; providing you with information about services, features, surveys, newsletters, offers, promotions, contests and events; providing other news or information about us and our select partners; and sending you technical notices, updates, security alerts, and support and administrative messages. Generally, you have the ability to opt out of receiving any promotional communications as described below under “Your Choices”;
Monitor and analyze trends, usage, and activities in connection with Cognology Services and for marketing or advertising purposes;
Investigate and prevent unauthorized access to Cognology Services, and other illegal activities;
Enable you to communicate, collaborate, and share Content with users you designate; and
For other purposes about which we notify you.
Notwithstanding the foregoing, we will not use Personal Information appearing in our Web Logs for any purpose.
Compiling aggregate analytics information: Because our SaaS Products and Downloadable Products are some of the most configurable in the market, we make extensive use of analytics information (including log and configuration data) to understand how our products are being configured and used, how they can be improved for the benefit of all of our users, and to develop new products and services. As such we generate Usage Data (as defined above) from the web logs and analytics logs described above, including the Content elements captured in such logs, as well as from the Content stored in the Websites and SaaS Products.
We also compile aggregate data to determine industry averages and create benchmarks. This aggregate data may be provided to third parties.
We will not share or disclose any of your Personal Information or Content with third parties except as described in this policy. We do not sell your Personal Information or Content.
Your use: When you use Cognology Services, Content you provide will be displayed back to you. Certain features of Cognology Services may allow you to make some of your Content public, in which case it will become readily accessible to anyone. We urge you to consider the sensitivity of any data you make public.
Collaboration: As a natural result of using Cognology Services, you may create Content and grant permission to other Cognology users to access it for the purposes of collaboration. Some of the collaboration features of Cognology Services display your profile information, including Personal Information included in your profile, to users with whom you have shared your Content. Where this information is sensitive, we urge you to use the various security and privacy features of the Cognology Services to limit those who can access such information.
Access by your system administrator: You should be aware that the administrator of your instance of Cognology Services may be able to:
access information in and about your Cognology Services account;
disclose, restrict, or access information that you have provided or that is made available to you when using your Cognology Services account, including your Content; and
control how your Cognology Services account may be accessed or deleted.
Service Providers, Business Partners and Others: We work with third party service providers to provide website, hosting, maintenance, back-up, storage, virtual infrastructure, payment processing, analysis and other services for us. These third parties may have access to or process your Information as part of providing those services for us.
Third party applications: You may choose to make use of third party Add-Ons in conjunction with Cognology Services. Third party Add-Ons are software written by third parties to which you grant access privileges to your Content (which may include your Personal Information). When access is granted, your Content is shared with the third party. Third party Add-On policies and procedures are not controlled by Cognology even though the third Party Add-On may be available through Cognology. Third parties who have been granted access to your Content through Add-Ons could use this data to contact you and market services to you, and could share your data with other third parties. This Privacy Policy does not cover the collection or use of your data by third party Add-Ons, and we urge you to consider the privacy policies governing third party Add-Ons.
Third Party Cookies and Tracking Technologies. When you visit Cognology’s Websites, third parties such as our advertising partners may use cookies, web beacons, and other technologies to collect information about your online activities over time and across different websites or online services. You may be able to opt out of receiving personalized advertisements as described below under “Your Choices.”
Compliance with Laws and Law Enforcement Requests; Protection of Our Rights: We may disclose your Information (including your Personal Information) to a third party if (a) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request, (b) to enforce our agreements, policies and terms of service, (c) to protect the security or integrity of Cognology’s products and services, (d) to protect Cognology, our customers or the public from harm or illegal activities, or (e) to respond to an emergency which we believe in the good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.
Business Transfers: We may share or transfer your information (including your Personal Information) in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Aggregated or Anonymised Data: We may also share aggregated or anonymised information that does not directly identify you with the third parties described above.
With Your Consent. We will share your personal information with third parties when we have your consent to do so.
For the avoidance of doubt, we may disclose your personal information to other third parties who provide services of any kind to us or to our clients under an agreement with us.
We do not share Personal Information about you with third parties for their marketing purposes (including direct marketing purposes) without your permission.
Cognology hosts data with hosting service providers in Australia. The servers on which Personal Information is stored are kept in a controlled environment. While we take reasonable efforts to guard your Personal Information, no security system is impenetrable and due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers. In addition, we cannot guarantee that any passively-collected Personal Information you choose to store in Websites or SaaS Products are maintained at levels of protection to meet specific needs or obligations you may have relating to that information.
Where data is transferred over the Internet as part of a Website or SaaS Product, the data is encrypted using industry standard SSL (HTTPS).
Where Downloadable Products are used, responsibility of securing access to the data you store in the Downloadable Products rests with you and not Cognology. We strongly recommend that administrators of Downloadable Products configure SSL to prevent interception of data transmitted over networks and to restrict access to the databases and other storage used to hold data.
You may opt out of receiving promotional communications from Cognology by using the unsubscribe link within each email to have your contact information removed from our promotional email list or registration database. Although opt-out requests are usually processed immediately, please allow ten (10) business days for a removal request to be processed. Even after you opt out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding Cognology’s Services.
You may be able to opt out of receiving personalized advertisements from companies who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising. For more information about this practice and to understand your options, please visit: http://www.aboutads.info and http://www.networkadvertising.org/choices/.
You can access and amend some of the information we keep about you through your account settings.
You agree not to use the Cognology Services in a manner that would violate laws protecting an individual’s privacy rights, health or financial data.
Cognology Services are not directed to individuals under 13. We do not knowingly collect Personal Information from children under 13. If we become aware that a child under 13 has provided us with Personal Information, we will take steps to delete such information. If you become aware that a child has provided us with Personal Information, please contact our Support Services.
If you are visiting from the European Union, United States or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your Personal Information to Australia. By providing your Personal Information, you consent to any transfer and processing in accordance with this Policy.
In the event that there is a data breach we will take all reasonable steps to contain the suspected or known breach where possible. We will take immediate steps to limit any further access or distribution where possible.
If we have reasonable grounds to suspect that the data breach is likely to result in serious harm to any individuals involved, then we will take all reasonable steps to ensure an assessment is completed within 30 days of the breach or sooner if possible. We will follow the guide published by the Office of the Australian Information Commissioner (if any) in making this assessment.
If we reasonably determine that the data breach is not likely to result in serious harm to any individuals involved or any remedial action we take is successful in making serious harm no longer likely, then no notification or statement will be made.
Where, following an assessment and undertaking remedial action (if any), we still have reasonable grounds to believe serious harm is likely, as soon as practicable, we will provide a statement to each of the individuals whose data was breached or who are at risk. The statement will contain details of the breach and recommendations of the steps each individual should take. We will also provide a copy of the statement to the Office of the Australian Information Commissioner.
We will then review the incident and take action to prevent future breaches.
If you have any questions about this privacy policy, any concerns or feedback regarding the treatment of your privacy, please use the contact link on our website or contact our Privacy Officer using the details set out below.
We will treat your requests or complaints confidentially. Our representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in timely and appropriate manner.
Please contact our Privacy Officer at:
Privacy Officer
Post: Cognology, Level 35, 600 Bourke Street, Melbourne 3000
Email: service@cognology.com.au
If we do not resolve your enquiry, concern or complaint to your satisfaction or you require further information in relation to any privacy matters, please contact the Office of the Australian Information Commission at:
Telephone: 1300 363 992
Email: enquiries@oaic.gov.au
Office Address: Level 3, 175 Pitt Street, Sydney NSW 2000
Postal Address: GPO Box 5218, Sydney NSW 2001
Website: www.oaic.gov.au
Cognology will not provide your email to a third party. We will periodically use your email information for news, sales and marketing purposes. If you wish to opt out of receiving such messages, you may unsubscribe here: https://cognology.com.au/unsubscribe
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