Privacy Policy

This Privacy Policy (“Privacy Policy”) describes the privacy practices related to the handling of Personal Information (defined below) of Cognitive Contractor LLC, a Texas corporation, and our subsidiaries and affiliates (collectively, “Cognitive Contractor”, “we”, “us”, or “our”) in connection with the https://www.cognitivecontractor.com website, and any other website or service that we own or control and which posts or links to this Privacy Policy (collectively, the “Service”), and the rights and choices available to individuals with respect to their Personal Information (as defined below).

This Privacy Policy applies to all users of the Service and all individuals whose Personal Information we store, including, but not limited to individuals who use, view, or otherwise access our Services, individuals who apply to work for Cognitive Contractor or otherwise provide Personal Information to Cognitive Contractor in connection with inquiries regarding opportunities at Cognitive Contractor, current and former Cognitive Contractor personnel, and other individuals whose Personal Information we receive from third parties or otherwise collect.

Cognitive Contractor may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect Personal Information. These supplemental privacy policies will govern how we may process such Personal Information in the context of the specific product or service. We may additionally create products or services for third parties that may contain their own privacy policies. Please review those privacy policies to learn more about how those products or services handle Personal Information.

We provide important information for residents of California below.

Cognitive Contractor is committed to supporting consumer privacy. We apply privacy principles throughout our business and continuously monitor applicable regulations and evaluate how we can further protect consumer information we process.

Personal Information Cognitive Contractor Collects and How We Collect It

Cognitive Contractor Services And Other Information Provided Directly to Cognitive Contractor

For purposes of this Privacy Policy, “Personal Information” means any information relating to an identified or identifiable individual. Cognitive Contractor does not collect Personal Information from you except when you specifically provide such information on a voluntary basis. Personal Information may be gathered from registration forms, content submissions or through our Services. As further described below, the Personal Information we may collect from you includes name, email address, mailing address, telephone number, contact preferences and other identifiers.

Information Received From Third Parties

We may receive Personal Information from third parties, such as publicly available information from government agencies, government departments, and other governmental organizations, information from consumer surveys, and information from other third-party data providers and sources.

Personal Information we may collect through the above categories of sources includes, but is not limited to:

• Business and personal contact information, such as your first and last name, email and mailing addresses, phone number, professional title and company name.
• Consumer Information, such as retail transactions data, vehicles you currently or previously own or lease, real property information, data related to insurance products, voter information, travel data, geographic data, recreational activity data, and birthday and other milestone date data.
• Automotive Information, such as VINs, and using the VINs we may append other auto-related information from public government-provided sources such as make, model, year, manufacturer, engine size, and vehicle class size.
• Demographic Information, such as protected class information (including race, color, age, and self-reported medical condition), national origin, religion, ethnicity, marital status, and gender.
• Inference Information created using any information we collect or receive about you to create a consumer profile reflecting your inferred consumer preferences, characteristics, behavior, attitudes, and more.
• Registration information, such as information that may be related to a service or a Cognitive Contractor account you register for to the extent such functionality is made available.
• Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online.
• Usage and Electronic information, such as information about how you use the Service and interact with us, including information associated with any content you upload to the Services or otherwise submit to us, information you provide when you use any interactive features of the Service, IP address, MAC address, or other hardware identifier for the device you used to access the Services, mobile identifiers, cookie identifier, browser or device information, and analytics information about your use of the Services, and any of the foregoing regarding your use of other websites such as internet search history, browsing history, your interactions with websites, pages visited, and advertisements with which you interacted.
• Marketing information, such as your preferences for receiving communications about our business, and details about how you engage with our communications.
• Social Media Information, such as social media URL, social media alias, and other social media profile data, including when you provide the foregoing in support or help interactions with us.
• Other information that we may collect which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.

If you choose to apply to work with or for Cognitive Contractor through our Services or by otherwise contacting us regarding opportunities, we may collect the following:

• Contact Information, such as your first and last name, email and mailing addresses, phone number, professional title and company name.
• Resume Information, such as qualifications, skills, employment or education history, or other resume information.
• Social Media Information, such as if you provide us a link to or other access to a social media account, we may collect or access any information you permit to be shared through or from your social media account and other information depending on the social media platform.

Minors

The Services are not directed to individuals under the age of eighteen (18), and we request that these individuals do not provide Personal Information through the Services. If you believe that we have mistakenly or unintentionally collected Personal Information of a minor through our Services without appropriate consent, please notify us as set forth below so that we may immediately delete the information from our servers and make any other necessary corrections. Note that we may store some Personal Information of minors as necessary to comply with applicable laws or as permitted by applicable laws (including honoring opt-out requests), and in such a case, we will retain only the minimum amount of information necessary or permitted.

How We Use Personal Information

Cognitive Contractor helps businesses market more effectively by providing marketing data products created using Personal Information collected as set forth above (“Products”) that help them learn valuable insights and understand more about their clients and prospects.

Our Products analyze client and prospect data to allow businesses to provide more targeted and meaningful offers, messages and customer experiences in an offline and online context.

Our Products are designed to provide more insight and contact information on individuals and households in the US.

More specifically, we may use your Personal Information for the following business purposes and as otherwise described in this Privacy Policy or at the time of collection:

To operate the Service. We may use your Personal Information to:

• provide, operate, and improve the Service and Products
• provide information about our Services and Products
• establish and maintain your user profile on the Service
• enable security features of the Service or Products, such as by sending you security codes via email or SMS notification, and remembering devices from which you have previously logged in
• communicate with you about the Service and Products, including by sending you announcements, updates, security alerts, and support and administrative messages
• communicate with you about events in which you participate
• understand your needs and interests, and personalize your experience with the Service and Products and our communications
• provide support and maintenance for the Service and Products
• respond to your requests, questions, and feedback

For research and development. We may analyze use of the Service and Products to optimize and improve them and to develop new services and products.

To send you marketing and promotional communications. We may send you Cognitive Contractor-related marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in this Policy.

To display advertisements. We may work with advertising partners to display advertisements on the Service or elsewhere online. These advertisements are delivered by our advertising partners and may be targeted based on your use of the Service or your activity elsewhere online. To learn more about your choices in connection with advertisements, please see the section below titled “Targeted online advertising.”

For compliance, fraud prevention, and safety. We may use your Personal Information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) comply with applicable laws, lawful requests, and legal process; (b) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (c) enforce the terms and conditions that govern the Service and Products; (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity; and (e) conduct, complete, or respond to audits or audit results.

With your consent. In some cases, we may specifically ask for your consent to collect, use or share your Personal Information, such as when required by applicable law.

To process applications. We may use your Personal Information to review and evaluate your applications to work with or for Cognitive Contractor or otherwise respond to you regarding such inquiries.

To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated, or de-identified data from your Personal Information and other individuals whose Personal Information we collect. We make Personal Information into anonymous, aggregated, or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated, or de-identified data and share it with third parties for our lawful operational purposes, including to analyze and improve the Service and Products and promote our operations.

For other operational purposes. Subject to this Privacy Policy, we may use your Personal Information to engage in other legitimate operational purposes as required or permitted by applicable law.

How We Share your Personal Information

We may share your Personal Information as described below:

Affiliates. We may share your Personal Information with subsidiaries and affiliates for purposes consistent with this Privacy Policy.

Service providers. We may share your Personal Information with third party companies, consultants, and individuals that provide services on our behalf or help us operate the Service or provide our Products (such as hosting, infrastructure, email delivery, marketing, and database management services). These third parties may use your Personal Information only as directed or authorized by us and in a manner consistent with this Privacy Policy and are prohibited from using or disclosing your information for any other purpose.

Sale of Products. We may sell Personal Information contained as more fully described below under Information for California Residents.

Professional advisors. We may disclose your Personal Information to professional advisors, such as bankers, auditors, insurers, and attorneys, where necessary in the course of the professional services they render to us.

For compliance, fraud prevention and safety. We may share your Personal Information for the compliance, fraud prevention, and safety purposes described above.

Business transfers. We may transfer or otherwise share some or all of our operations or assets, including your Personal Information, in connection with a transaction (or potential transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or transfer of assets, where any Personal Information included in such transfer is subject to protections no less restrictive than those herein.

With your consent. We may otherwise share your Personal Information with your consent or pursuant to your instructions.

For other operational purposes. Subject to this Privacy Policy, we may share your Personal Information for other legitimate operational purposes as required or permitted by applicable law.

Retention

We retain Personal Information for as long as necessary to fulfill the purposes for which we collected or received it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, for fraud prevention purposes, or suppression (to remove certain information from our Products and Services or prevent it from being retained).

Factors that inform our data retention periods include the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of the Personal Information, the purposes of processing, whether we can achieve those purposes through other means, and applicable regulatory or other legal requirements.

When we no longer require Personal Information, we will either delete or anonymize it or, if this is not possible (for example, if it is stored in backup archives), then we will securely store the Personal Information and cease further processing until deletion is possible. If we anonymize Personal Information (so that it can no longer be associated with an individual), we may retain the anonymized information for longer periods.

Your Choices and How to Contact Us

Opting Out of our Products

To request to be removed from our Products, please review the Information for California Residents section below. However, please note that submitting requests to be removed from our Products will not prevent other companies from retaining your Personal Information, sending you direct marketing materials, or making telemarketing calls. Please contact those companies to inquire about requests for deletion from their systems.

Access to Personal Information

Though not necessarily required by applicable laws in your area, we may elect to provide tools that allow you to request access to learn what Personal Information we process about you and your household. To access this information, please review the Information for California Residents section below. You may also request access to Personal Information we otherwise collected about you through the Services, for example, if you provided us Personal Information directly, by contacting us via email at privacy@cognitivecontractor.com.

Information for California Residents

CCPA (California Consumer Privacy Act)

If you are a California resident, you may have the right to disclosure of information about our collection, sale, or disclosure for a business purpose of your Personal Information, including, to the extent applicable, the following:

• The categories of Personal Information about you that Cognitive Contractor collected
• The categories of sources of Personal Information we collected
• The categories of third parties with whom we shared your Personal Information
• The business or other purposes for which we collected or sold your Personal Information
• The categories of such Personal Information we sold or disclosed for a business purpose, by category for each category of third parties to whom the Personal Information was sold or disclosed, or we will state that we have not sold or disclosed for a business purpose such consumer’s Personal Information.
• The specific pieces of Personal Information we have collected about you.

We collect Personal Information set forth above from the following categories of third-party data providers and sources:

• Apparel & Accessory Companies
• Automotive Companies
• Business to Business Companies
• Consumer Inquiries About Cognitive Contractor Products/Services
• Consumer Packaged Goods Companies
• Consumer Survey Companies
• Consumers
• Electronics Companies
• Financial Services Companies
• Food & Beverage Companies
• Gift Product Companies
• Government and other Public Sources
• Health Product Companies
• Insurance Product Companies
• Lifestyle & Interest Product Companies
• Not for Profit Organizations
• Online & Mobile Websites & Apps
• Other Authorized Data Compilers
• Other Product Companies Not Categorized
• Parenting Product Companies
• Publishing Product Companies
• Telecommunications Companies
• Travel, Leisure & Entertainment Companies

We may disclose the categories of personal information set forth above to the following categories of third parties for business purposes:

• Service Providers
• Public or Government Entities
• Advertising Networks
• Internet Service Providers
• Data Analytics Providers
• Operating Systems and Platforms
• Social Networks
• Consumer Data Resellers

We may sell Personal Information set forth above to the following categories of recipients:

• Automotive Companies
• Business Services/Agency
• Consumer Services Companies
• Consumer Packaged Goods Companies
• Data Companies
• Educational Institutions & Companies
• Energy and Utility Companies
• Financial Services Companies
• Food & Beverage Companies
• Health Product Companies
• Insurance Companies
• Manufacturing Companies
• Marketing and Research Companies
• Media and Publishing Companies
• Not for Profit Organizations
• Public Institutions
• Retail Companies
• Technology/Computer Software Companies
• Telecommunications Companies
• Travel, Leisure & Entertainment Companies
• Other Companies not Categorized

Right to Opt Out Of Future Data Sale:

Certain California residents may have the right to opt out of the sale of their Personal Information for marketing purposes by following the below instructions. During the 12 months preceding the last revision date of this Privacy Policy, Cognitive Contractor has sold Personal Information as set forth above by licensing and selling our Products and Services to our business clients for their commercial, business, marketing, and information analysis activities. We do not sell Personal Information to consumers.

Right to Know:

Certain California residents have the right to know what Personal Information we store about them by following the below instructions. Note that the information we provide in a Right to Know request represents a sample of the Personal Information we store about a consumer. We may store other information that may not be related to that consumer or which is overly technical and would likely not be reasonably meaningful or helpful to a consumer.

Right to Deletion:

Certain California residents have the right to request deletion of their Personal Information by following the below instructions. We may, to the extent permitted under the CCPA and other applicable laws, retain and continue to process Personal Information in accordance with certain exceptions.

Non-Discrimination:

California residents have the right not to receive discriminatory treatment for exercising any of the privacy rights conferred by the CCPA, except as permitted under the CCPA. If you believe you have received discriminatory treatment by Cognitive Contractor for exercising your CCPA privacy rights, please contact us as set forth below.

Submitting Requests:

Do not send us, directly or indirectly, any sensitive or special categories of Personal Information (e.g., social security numbers or other national or state identifiers, health information, biometric data or genetic characteristics, criminal background information, financial account numbers, payment card information, and so on) on or through the Services or otherwise. We do not require and do not request any sensitive or special categories of Personal Information in connection with our provision of the Products or Services, and it is not needed to respond to your requests.

If you would like to submit your request, or if you would like to opt out of sale of your Personal Information, please complete this Personal Information Request Form and email your request to privacy@cognitivecontractor.com. We may choose to make the above rights available to residents in other US states as well even if the laws in such states do not provide for the same rights as California. Any requests sent via email must be made using the Personal Information Request Form and include your first name, last name, address, city, state, ZIP code and phone number, as indicated on the Form. We will evaluate and respond to your request to the extent required by law (or in our discretion if not required by law) and as permitted by our contracts, confidentiality obligations, and applicable laws and regulations. We may not be able to provide all of the information requested due to certain exceptions enumerated in the CCPA or other applicable laws. If we do not have sufficient information about you to verify your identity, we may not be able to identify you and will be unable to process your request. We will attempt to verify your identity by using the information you submit with your request matching it with the information we possess about you. We may need to request additional information to sufficiently identify you.

If you are a third party or an agent, please submit this form together with the below applicable information to privacy@cognitivecontractor.com.

Authorized Agents

Authorized agents must submit the following written documentation.

Authorized agents operating as a business must provide:

1. Certificate of good standing with the state of incorporation;
2. Written authorization document that includes each consumer’s name, address, telephone number and valid email address, signed and dated by each consumer authorizing the business as the authorized agent to act on behalf of each consumer in making the request;
3. Valid email address for each consumer for our direct correspondence with each consumer, including as deemed necessary or legally required completion of an identity verification process.

If you are an individual and acting as an authorized agent on behalf of a consumer, please provide:

1. A “power of attorney” signed and dated by the consumer and notarized by a notary public naming the agent as the consumer’s authorized representative, which includes the consumer’s full name, and physical address, month/year of birth;
2. If no power of attorney is available, then provide a written authorization document that includes the consumer’s name, address, telephone number and valid email address, signed by the consumer authorizing the agent to act as the authorized agent on behalf of the consumer;
3. Valid email address for each consumer for our direct correspondence with each consumer, including as deemed necessary or legally required completion of an identity verification process.

Parent/Guardian of Minor Child*

If you are a parent or guardian of a minor child under 18 and would like to make a request for a right to know or deletion on behalf of the minor child, please provide the following:

• The minor’s verification documents (all are required):
• A certified copy of the minor’s birth certificate or adoption decree
• Health insurance card (issued by the insurance company)
• Medicare/Medicaid are accepted
• Certified school record or transcript or home school notice of intent form that includes minor’s permanent address
• Proof of parental/guardianship identity document that matches the minor’s permanent residence, which includes one of the following:
• Minor’s court order establishing custody
• Minor’s order establishing guardianship
• Court issued parental responsibility (for example, court documents on file with presiding court)
• Current month’s utility bill with parent/guardian’s name and address shown

* For the safety and security of the minor child, no location information will be provided in any Personal Information Request report issued.

“Shine the Light” Law

In accordance with the California Shine the Light law, California residents may request certain information regarding our disclosure (if any) of Personal Information to third parties for their direct marketing purposes. Other than to third party recipients as set forth in this Privacy Policy (“How We Share Information”), or unless you request us to or consent to it, we do not share your Personal Information with third parties for their own direct marketing purposes. For any questions on these practices, please contact us as set forth below.

EU-US Data Privacy

We do not as a matter of course collect or store Personal Information on or about individuals located in the European Union.

Other Important Information

Data Accuracy

Cognitive Contractor maintains quality control procedures to ensure the Personal Information we store is as accurate and complete as reasonably possible. We have developed proprietary technology to constantly evaluate the accuracy of the Personal Information we store, identify inaccurate Personal Information, and update the Personal Information as applicable and as reasonably practicable.

Links to Third Party Sites

Our Products and Services may contain links to unaffiliated third-party sites. Cognitive Contractor and its affiliate sites do not endorse or make any representations about any third-party sites including any information found on such sites. We encourage you to review the privacy policies and terms of use of these unaffiliated third-party sites.

Security

Cognitive Contractor maintains organizational, technical and physical security procedures, including those required by applicable laws, designed to protect Personal Information we store from accidental or unlawful destruction or accidental loss, damage, alteration, unauthorized disclosure or access, as well as all other forms of unlawful processing. Measures are taken to prevent unauthorized access, alteration, or dissemination of personal information. We also maintain physical security for our facilities and limit access to certain critical areas of our business. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your Personal Information.

If we learn of and confirm the occurrence of a security incident leading to the misappropriation or accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, your Personal Information transmitted, stored or otherwise processed on our systems that compromises the confidentiality, integrity or availability of your Personal Information, we may attempt to notify you electronically by posting a notice on our Services or by sending you an email or otherwise in accordance with applicable law.

Changes to This Policy

Cognitive Contractor may revise this Privacy Policy from time to time. Any changes to this Privacy Policy will be posted here or other successor locations available from this page. You can determine when this Policy was last revised by checking the “Last Revised” legend at the bottom of this Policy.

Questions

If you have any questions about Cognitive Contractor’s Privacy Policy or how we process your Personal Information, you may email us privacy@cognitivecontractor.com. You may also submit privacy and personal information requests by completing this form and emailing it to us. We will evaluate and respond to your request to the extent required by law (or in our discretion if not required by law) and as permitted by our contracts, confidentiality obligations, and applicable laws and regulations.

Last Updated: November 2020