This Online and Mobile Privacy Policy ("Privacy Policy") explains how information is collected, used and disclosed by Cognni Limited ("Cognni"), and applies to information we collect when you use or access our online or mobile websites (www.cognni.com), products, services or applications (collectively, the "Cognni Services"), or when you otherwise interact with us. We respect the privacy rights of users and recognize the importance of protecting information collected about you. If you use the Cognni Services as part of an entity or organization that has an agreement with Cognni (like your employer), the terms of that organisation's contract for the Cognni Services may restrict our collection or use of your information more than what is described in this Policy.

Changes to This Policy

We may change this Privacy Policy from time to time. If we make any changes, we will notify you by revising the "Last Updated" date at the top of this Privacy Policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you an email notification). If there are material changes to this Privacy Policy, we will notify you more directly by email or means of a notice on the home page prior to the change becoming effective. We encourage you to review our Privacy Policy whenever you access the Cognni Services to stay informed about our information practices and the ways you can help protect your privacy. Your use of any of the Cognni Services after the posting of such changes shall constitute your consent to such changes.

Information Collected

Information You Provide To Us. We collect information you provide directly to us.

For example, we collect information when you register with Cognni for an account, create or modify your profile and online account, access and use the Cognni Services (including but not limited to when you upload, download, collaborate on or share files or other information), participate in any interactive features of the Cognni Services, participate in a survey, contest, promotion, sweepstakes, activity or event, make a purchase, apply for a job, request customer support, communicate with us via third-party social media sites or otherwise communicate with us. The types of information we may collect directly from you include your name, username, email address, your picture, postal address, phone number, information about your data storage preferences, employer's name, job title, transactional information (including services purchased or subscribed to and billing address) as well as any contact or other information you choose to provide. Please be aware that the information you choose to provide in your Cognni profile may reveal or identify information that is not expressly stated (for example, if you choose to provide your picture, your picture may reveal your gender. We also store the files or other information that you upload or provide to the Cognni Services ("Content") in order to be able to provide you with the features and functionality of the Cognni Service. Unless you have purchased a Cognni Enterprise account or higher Cognni Service offering and you have entered into a Business Associate Addendum to the Cognni Service Agreement, you agree not to upload and/or collaborate Protected Health Information ("PHI") as defined under the Health Insurance Portability and Accountability of 1996 Act as amended ("HIPAA"); Cognni disclaims all liability for such PHI. Information We Collect Automatically When You Use the Cognni Services. When you access or use the Cognni Services, we may automatically collect information about you, including:

Usage Information: We monitor user activity in connection with the Cognni Services and may collect information about the applications and features you use, the websites you visit, the sizes and names of the files or folders you upload, download, share or access while using the Cognni Services, the Content you access and any actions taken in connection with the access and use of your Content in the Cognni Services. Log Information: We log information about you when you access and use the Cognni Services including your Internet Protocol ("IP") address, access times, browser type and language, Internet Service Provider ("ISP"), the Web pages that you visit, the Content you use and the URL of the Web page you visited before navigating to the Cognni Services. Device Information: If you access the Cognni Services from a mobile device, we collect information about the device, including the hardware model, operating system and version, unique device identifiers, mobile network information (as allowed by the mobile network) or platform information (as allowed by the specific platform type). We do not ask for, access or track any location based information from your mobile device at any time while downloading or using our mobile apps. Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information, which may include saving cookies to your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory that help us to improve the Cognni Services and your experience, customize your experience and preferences, allow you to access and use the Cognni Services without re-entering your user ID and/or password, understand which areas and features of the Cognni Services are most popular and count visits. We may also collect information using web beacons (also known as "tracking pixels"). Web beacons are electronic images (also called "gifs") that may be used in the Cognni Services or in emails that help us to deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon. Third party cookies: the use of cookies by third parties you may sign-in from into the Cognni Services and/or third party applications is not covered by our privacy policy. We do not have access or control over such cookies.

Information We Collect From Other Sources. We may also obtain information from third parties and combine that with information we collect through the Cognni Services. For example, we may have access to certain information from a third-party social media service if you create or log into your online account 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 media service is in accordance with the authorization procedures determined by the social media service.

Use of Information

We may use the information we collect about you for a variety of purposes, including to:

Provide, operate, maintain and improve the Cognni Services; Enable you to access and use the Cognni Services, including uploading, downloading, collaborating on and sharing Content and sending emails on your behalf; Send you technical notices, updates, security alerts and support and administrative messages; Provide and deliver the services and features you request, process and complete transactions, and send you related information, including purchase confirmations and invoices; Respond to your comments, questions, and requests and provide customer service and support; Communicate with you about services, features, surveys, newsletters, offers, promotions, contests and events, and provide other news or information about Cognni and our select partners; Monitor and analyze trends, usage, and activities in connection with the Cognni Services and for marketing or advertising purposes; Investigate and prevent fraudulent transactions, unauthorized access to the Cognni Services, and other illegal activities; Personalize and improve the Cognni Services, and provide content, features, and/or advertisements that match your interests and preferences or otherwise customize your experience on the Cognni Services; Link or combine with other information we receive from third parties to help understand your needs and provide you with better service; Enable you to communicate, collaborate, and share files with users you designate; and For other purposes about which we notify you. Processing

By accessing or using the Cognni Services or otherwise providing information to us, you consent to the processing and transfer of information in and to the U.K. and other countries and territories, which may have different privacy laws from your country of residence.

Sharing and Disclosure of Information.

We will not share personal information about you or any Content with any third parties except as described in this Privacy Policy or in connection with the Cognni Services. For example, we may share personal information about you including as follows:

Vendors, Consultants and Other Service Providers: We may share your information with third-party vendors, consultants and other service providers who are working on our behalf and require access to your information to carry out that work, such as to process billing, provide customer support, etc. For Collaboration: We may share your information, including when you choose to use collaboration features in the Cognni Services that by their nature support sharing with third parties who you choose. Your name, email address, information from your profile and online account (including your photo), and any Content you choose to share will be shared with such third parties, and such third parties may communicate with you (such as by posting comments or emailing you) in connection with your use of the collaboration features of the Cognni Services. Compliance with Laws: We may disclose your 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 the Cognni Services, (d) to protect Cognni, 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 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 Anonymized Data: We may also share aggregated or anonymized information with third parties that does not directly identify you. Security

While no service is completely secure, Cognni takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. For example, your Content is protected with encryption, such as Secured Socket Layer (SSL) protocol, during transmission over the Internet.

The network on which personal information is stored are kept in a controlled environment with limited access. While we take reasonable efforts to guard personal information we knowingly collect directly from you, no security system is impenetrable. In addition, we cannot guarantee that any passively-collected personal information you choose to include in documents you store on our systems are maintained at levels of protection to meet specific needs or obligations you may have relating to that information.

You may access your account information and our service only through the use of an individual user ID and password. To protect the confidentiality of personal information, you must keep your password confidential and not disclose it to any other person. Please advise us immediately if you believe your password has been misused. In addition, always logout and close your browser when you finish your session. Please note that we will never ask you to disclose your password in an unsolicited phone call or email.

Your Choices

Account Information & Retention. You may update, correct or delete information about you at any time by logging into your online account and modifying your information or by emailing us at info@cognni.com. We will retain your personal information for the period necessary to fulfil the purposes outlined in this Privacy Policy. If you wish to deactivate your account, please email us at info@cognni.com, but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time. We will respond to your access request within 30 days. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information to comply with our legal obligations, resolve disputes and enforce our agreements.

Promotional and Newsletter Communications. You may opt out of receiving promotional and newsletter emails from Cognni by following the opt-out instructions provided in those emails. You may also opt-out of receiving promotional emails and other promotional communications from us at any time by emailing info@cognni.com with your specific request. If you opt out, we may still send you non-promotional communications, such as security alerts and notices related to your access to or use of the Cognni Services or those about your online account or our ongoing business relations.

Cookies. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies or to prompt you before accepting such a cookie. Please note that, if you choose to remove or reject browser cookies, this could affect the availability or functionality of the Cognni Services.

Social Media Features and Widgets

The Cognni Services may include social media features. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on a Cognni Service. Your interactions with these features are governed by the privacy policy of the company providing it.

Links to Third Party Websites

We may place links on the Cognni Services. When you click on a link to a third party website from our website, your activity and use on the linked website is governed by that website's policies, not by those of Cognni. We encourage you to visit their websites and review their privacy and user policies.

Our Policy Toward Children

The Cognni Services are not directed to individuals under 13. We do not knowingly collect personal information from children under 13. If you become aware that a child has provided us with personal information, please contact us at info@cognni.com. If we become aware that a child under 13 has provided us with personal information, we will take steps to delete such information.

Contacting Us

Any questions about this Privacy Policy should be addressed to info@cognni.com or to Jason House, Kerry Hill, Horsforth, Leeds, LS18 4JR.

Last Updated: June 2022