This privacy policy (the “Privacy Policy”) governs how we, Qognify Ltd., its subsidiaries and affiliates worldwide (“Qognify” “we”, “our” or “us”) use, collect and store information pertaining to you (“User” or “you”), for example in the following use cases:

  • When you make use of our website, qognify.com (the “Website”);
  • When you represent a company using our services;
  • When you represent a company we engaged for the provision of services;
  • When you commence direct communication with us;
  • When you submit your resume for one of the positions listed on our Website; or
  • When you exchange business cards with us, or provide other Personal Data (as defined below) when attending a marketing event or trade show.

At Qognify, we greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, in order to fully understand our practices in relation to Personal Data. The term “Personal Data” means any information that can be used, alone or together with other data, to uniquely identify any living human being.

Table of Contents:

  • What Information We Collect; Why We Collect it; and How it is being Used;
  • How We Protect and Store your Personal Data;
  • How We Share your Personal Data;
  • Additional Information Regarding Transfers of Personal Data;
  • Your Rights;
  • Use by Children;
  • How to Contact Us

This Privacy Policy may be updated from time to time for any reason and at our sole discretion. We therefore ask you to check back periodically for the latest version of the Privacy Policy, as indicated below. If there are any significant changes made to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or through other means.

  1. WHAT PERSONAL DATA WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS BEING USED
Personal Data We Collect Why is the data collected and for what purposes? Legal basis Third Parties with whom we Share your Data Period of Storage Consequences of not providing the Data

 
First and last name, email, phone number, and job title When you register to the partner portal on our Website, we need this information in order to open and manage your account. Necessary to perform a contract or take steps, at your request, to enter into a contract, Art. 6 (1) 1 lit b) GDPR. Salesforce (CRM system);
Marketo (marketing automation platform);NetSuite (ERP system)
Facebook (Social Media Platform)
LinkedIn (Social Media Platform)
Twitter (Social Media platform)
Google (Paid search and display campaigns)
Docebo (training portal)		 For as long as is reasonably necessary for us to adequately provide you with the services described on the Website. You will not be able to use the partner portal
When you represent a company we are currently working with or providing services to. Necessary to perform a contract or take steps, at your request, to enter into a contract, Art. 6 (1) 1 lit b) GDPR. For as long as we provide you with our services. We will not be able to contact you in connection with the services we provide.
When you represent a company we engaged for the provision of services. Necessary to perform a contract or take steps, at your request, to enter into a contract, Art. 6 (1) 1 lit b) GDPR. For as long as we engage you for your company’s services. We will not be able to adequately utilize the services your company provides.
When you commence direct communications with us, for example through the “Get In Touch” tab on the Website. Necessary to perform a contract or take steps, at your request, to enter into a contract, Art. 6 (1) 1 lit b) GDPR. For as long as reasonably necessary to respond to your inquiry. We will not be able to respond to your inquiry.
When you participate in a marketing event or tradeshow and provide us with Personal Data. Consent, Art. 6 (1) 1 lit a) GDPR. Until you choose to unsubscribe, as soon as reasonably practicable, and within a maximum period of 180 days. We will not be able to get in touch with you.
When you express your interest to receive marketing emails from us in order to learn more about our products and services. Consent, Art. 6 (1) 1 lit a) GDPR. Until you choose to unsubscribe, as soon as reasonably practicable, and within a maximum of 180 days. You will not be able to learn more about our products and services.
Resume When you choose to upload your resume, or link your linkedIn profile, so we can get in touch with you, should you meet the job requirements. Necessary to perform a contract or take steps to enter into a contract with you, Art. 6 (1) 1 lit b) GDPR. Comeet (a recruitment platform) 36 months We will not be able to contact you in relation to your application
  1. HOW WE PROTECT AND STORE YOUR INFORMATION
  1. Security. We have implemented appropriate technical, organizational and security measures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the information concerned. However, please note that we cannot guarantee that the information will not be exposed as a result of any unauthorized penetration to our servers. Nevertheless, we make commercially reasonable efforts to make the collection and security of such information consistent with this Privacy Policy and all applicable laws and regulations. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
  1. Retention of your Personal Data. In addition to the retention periods mentioned in Section 1 above, in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.
  1. HOW WE SHARE YOUR PERSONAL INFORMATION

In addition to the recipients described in Section 1, we may share your information as follows:

  • To the extent necessary, with regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies or if required to do so by a court order, on the legal basis of 6 (1) 1 lit c) and f) GDPR.;
  • If, in the future, we sell or transfer some or all of our business or assets to a third party, we will (to the minimum extent required) disclose information to a potential or actual third–party purchaser of our business or assets, on the legal basis of 6 (1) 1 lit f) GDPR., or in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign Personal Data in connection with the foregoing events on the legal basis of Art. 6 (1) 1 lit f) GDPR, except as required otherwise by applicable law.
  1. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL INFORMATION

We ensure transfers within the Qognify group will be covered by an agreement entered into by members of the Qognify group (an intra-group agreement) which contractually requires each member to ensure that Personal Data receives an adequate and consistent level of protection wherever it is transferred to;

Where we transfer your Personal Data outside of Qognify, for example to third parties who help provide our products and services, we will obtain contractual commitments from them to protect your Personal Data. Some of these assurances are well recognized certification schemes like the EU – US Privacy Shield for the protection of Personal Data transferred from within the EU to the United States; or

Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed; and

Where you have provided your consent to us using the Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).

  1. YOUR RIGHTS

The following rights (which may be subject to certain exemptions, exceptions or derogations), shall apply to individuals who are protected by the EU General Data Protection Regulation (GDPR):

  • You have a right to access information held about you. Your right of access is normally exercised free of charge, however, we reserve the right to charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the necessary actions where requests are manifestly unfounded or excessive, in particular because of their repetitive character (Art. 12 (5) 2 lit a) GDPR or requests for any further copies in addition to the first one requested (Art. 15 (3) 2 GDPR);
  • You have the right to request that we amend any Personal Data we hold that is inaccurate or misleading.
  • You have the right to request to delete or remove the Personal Data that relates to you. Please note that there may be circumstances in which we are required to retain your data, for example for the establishment, exercise or defense of legal claims;
  • The right to object to or to request restriction of the processing. However, there may be circumstances in which we are legally entitled to refuse your request;
  • The right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
  • You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority;
  • The right to withdraw your consent. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations;
  • You also have a right to request details of the basis on which your Personal Data is transferred outside the European Economic Area, but you acknowledge that data transfer agreements may need to be partially redacted for reasons of commercial secrecy and confidentiality.

You can exercise your rights by contacting us at Legal@Qognify.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Data requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

In the event that your request would adversely affect the rights and freedoms of others (for example, in the event it would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than the one initially requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

  1. DATA PROTECTION OFFICER

We have appointed a data protection officer for our company.

Qognify Limited
20-22 Wenlock Road
London, N1 7GU
United Kingdom
Mr. Gal Golod
Phone: +1-646-830-2639
Email: galg@qognify.com

Qognify Inc.
1 Blue Hill Plaza, 7th Floor
Pearl River, NY 10965
USA
Mr. Gal Golod
Phone: +1-646-830-2639
Email: galg@qognify.com

Qognify GmbH
Werner-von-Siemens-Str. 2 – 6
76646 Bruchsal
Mr. Nikolai Haas / CTM-COM GmbH
Phone: +49 6154 57605-111
Email: datenschutz@ctm-com.de

  1. US PRIVACY PROVISIONS
  1. California Civil Code Section 1798.83 (and other, similar state statutes) permits our customers who are California residents (or residents of states with similar legislation) to request certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes. To make a request of this type, please send an email to Legal@Qognify.com. Please note that we are only required to respond to one request per customer each year.
  1. Our Do Not Track Notice. We do not currently respond or take any action with respect to web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of Personal Data about a User’s online activities over time and across third-party web sites or online services. We do allow third parties who provide us with analytics tools, as described in Section 1, to collect Personal Data about a User’s online activities when a User uses the Website.
  • If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 allows you to remove content or Personal Data you have publicly posted. If you wish to remove such content or Personal Data and you specify which content or Personal Data you wish to be removed, we will do so in accordance with applicable law. Please be aware that after removal you will not be able to restore the removed content. In addition, such removal does not ensure the complete or comprehensive removal of the content or Personal Data you have posted and that there may be circumstances in which applicable law does not require us to enable removal of content.
  1. USE BY CHILDREN

We do not offer our products or services for use by children. If you are under 18, you may not use the Website, or provide any information to the Website without the involvement of a parent or a guardian. We do not knowingly collect information from, and/or about children.

  1. INFORMATION ABOUT THE RESPONSIBLE PARTY “REFFERED TO AS THE “CONTROLLER” IN THE GDPR

The data processing controllers on this website are:

Qognify Limited
35 Folgate St., Spitalfields
London, E1 6BX
United Kingdom
Mr. Gal Golod
Phone: +1-646-830-2639
Email: galg@qognify.com

Qognify Inc.
1 Blue Hill Plaza, 7th Floor
Pearl River, NY 10965
USA
Mr. Gal Golod
Phone: +1-646-830-2639
Email: galg@qognify.com

Qognify GmbH
Werner-von-Siemens-Str. 2 – 6
76646 Bruchsal
Mr. Nikolai Haas / CTM-COM GmbH
Phone: +49 6154 57605-111
Email: datenschutz@ctm-com.de

The controller is the natural person or legal entity that single-handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g. names, e-mail addresses, etc.).

  1. CONTACT US

If you have any questions, concerns or complaints regarding this Privacy Policy, our compliance with this notice and the applicable data protection laws or regulations, or if you wish to exercise your rights, we encourage you to first contact us at info@qognify.com