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Our Privacy Policy

This Privacy Policy describes how COGNITRO addresses data privacy with respect to information that it collects from visitors to this Web site (located at www.Cognitro.com) and from people and organizations that purchase products or services from COGNITRO. The Privacy Policy does not describe how COGNITRO treats information collected from individuals on behalf of its corporate clients. Either COGNITRO or its client will describe to you at the time you provide information under these circumstances how the information you provide will be used.

1. What information does COGNITRO collect from its customers and Web visitors, and how does COGNITRO use that information?

COGNITRO collects information necessary to conduct business with its customers and Web visitors, such as to provide you with the information or services you request. COGNITRO may also ask you to provide optional information, such as how you use COGNITRO products, so that we may better tailor our products and services to customer needs. We also collect information about how people make use of our Web site so we can make that experience more valuable. COGNITRO gathers two major types of information directly from customers and Web visitors: (1) information that current and prospective customers provide in the course of purchasing products or services from COGNITRO or expressing an interest in doing so; (2) information that Web site visitors actively provide through optional registration on our site. As we continue to improve our Web site, we will continue to add different products and services, and may collect information in order to provide you with those products and services. To the extent that any of our new methods include information collection or use not anticipated in this Privacy Policy, our new uses or policies will be disclosed to you before you provide us with information.

COGNITRO sends electronic newsletters to Web registrants and customers on a periodic basis, which varies according to the content you might choose to receive. We occasionally send out special communications when we think subscribers or customers might be particularly interested in something we are doing or a product or service we are offering, or when we wish to survey subscribers and customers. The amount and type of information you disclose to COGNITRO is at your discretion; you can choose not to provide us with information you don't wish to share. In some cases, however, this cannot be done selectively, and opting not to provide certain types of information may amount to non-participation in particular features and thus may affect the services available to you from COGNITRO. COGNITRO also collects information passively from its Web site visitors when they browse the COGNITRO Web site.

Please note that for any of the information described, COGNITRO may transfer it to a secure location in the United States, regardless of where you might reside.

2. With whom does COGNITRO share the personal information it collects at this Web site or from its customers?

COGNITRO does not share information it collects from you with other organizations that intend to use it for their own commercial purposes. We only share information with organizations who perform services for us, and only if they agree to restrict their use of your information to these purposes. Except as described below, COGNITRO does not, unless required by law, disclose personal information it collects to people or organizations outside of COGNITRO whose stated aim is to use it for any purpose other than to process your registration, fulfill your requests to COGNITRO, keep you informed about COGNITRO products and services, or some other task that COGNITRO asks them to perform on our behalf. For example, COGNITRO may contract with a data management services company, or with an outside organization that will send e-mail marketing messages on our behalf, and will share your personal information with those third parties so that they can assist us. COGNITRO may also share your information with an COGNITRO distributor near you in order to complete your request for products or services. In such instances, these organizations would be prohibited by COGNITRO from using your information for their own commercial purposes and from disclosing your information to a third party for that third party’s own commercial purposes. If another organization has acquired all or a substantial portion of COGNITRO’ business, either through merger, divestiture of particular product lines, consolidation, or a purchase of assets, customer information may be among the things acquired by that organization, and COGNITRO will provide your personal information to that organization. COGNITRO may also disclose your personal information to its corporate affiliates or subsidiaries. COGNITRO will also disclose your information if required by law to do so. COGNITRO occasionally works with non-affiliated partner organizations that provide products or services in which we think you might be interested. We do not share your information with these partner organizations without your permission. We may, however, send you a message on their behalf if you had already consented to receiving similar messages about COGNITRO products and services. For these partner organizations to obtain any personal information about you, you would have to provide it to them yourself.

3. How can I review and update personal information I submitted online?

If you have registered at the COGNITRO Web site, you can review and update information you provide there via the Web site itself. COGNITRO offers you the ability to correct and update the information you have previously provided to us at this Web site. When you are logged in, you will be able to view the personal information you have previously provided at our Web site and may make any adjustments you would like. You may change this information at any time, and as often as you like.

4. How can I opt out of electronic correspondence from COGNITRO?

You can opt out of electronic correspondence from COGNITRO at the Registration Page on our Web site, via the instructions provided in the correspondence itself, or by contacting COGNITRO and requesting to be removed from our mailing list. As described under #1 above, COGNITRO sends electronic newsletters to Web registrants and customers on a periodic basis, which varies according to the content you might choose to receive. We also occasionally send out special communications when we think subscribers or customers might be particularly interested in something we are doing or a product or service we are offering, or when we wish to survey subscribers and customers. Regardless of whether you have opted out of receiving unsolicited electronic correspondence from COGNITRO, we will still send you important transactional e-mail messages, for example, messages about your use of our Web site (such as any substantive changes to our Privacy Policy), or about products and services you may have obtained from us.

5. How does COGNITRO secure my information?

COGNITRO takes a variety of measures to secure your information from unwarranted access and accidental loss. COGNITRO takes reasonable precautions based on industry standards and best practices to protect the information that you provide to us from corruption, unlawful access and accidental loss. We employ a number of technical safeguards to protect the transmission, processing and storage of your information including the deployment of network access controls, message and file encryption, and logging technologies. We also implement operational safeguards to ensure that your information is handled or viewed only by COGNITRO-authorized personnel directly involved in the activities described above, including training personnel to follow COGNITRO' Information Protection Policy and taking appropriate disciplinary measures if they fail to do so.

6. How will I know if the COGNITRO Privacy Policy changes?

COGNITRO will post its updated policy on the "Privacy Policy" section of this Web site. We will also inform all contacts who provide us with their e-mail addresses of any substantive change to this Privacy Policy. If we need to change the conditions of the COGNITRO Privacy Policy, we will post an updated Privacy Policy on this Web site. We will indicate in the updated Privacy Policy its effective date. We will also send an e-mail notice if we make substantive changes to the Privacy Policy to everyone who has provided us with an e-mail address, so that they may review any new conditions and update their information or preferences accordingly. Consequently, even if you've opted out of receiving e-mail from COGNITRO, you might still receive such a notice, since it pertains to the very practices that ensure we have only the information you wish us to have and use it for purposes of which you approve.

7. To whom should I address questions about the privacy of my information held by COGNITRO? What can I do if I think COGNITRO has not adhered to this Privacy Policy and my privacy has been affected?

You can direct questions and reports of possible breaches of this Privacy Policy to the COGNITRO Legal Department. If you have reason to believe that COGNITRO has not adhered to the standards specified in this Privacy Policy, the COGNITRO Legal Department will investigate your concerns and propose an appropriate remedy on behalf of COGNITRO.

Effective January 2006
Note: This site contains links to other Web sites. COGNITRO Inc. is not responsible for the privacy practices or the content of those

Web sites.

Types of Information COGNITRO May Collect From Customers and Web Registrants Purchases

When you purchase products or services from COGNITRO, we collect from you the information needed to complete this transaction – e.g., your name, the name of your organization if applicable, shipping address, telephone number, and credit card information as necessary. If you are purchasing a license for multiple users of a software product, we may also ask you for the names of those users, so that they too may receive services such as technical support. A postage-paid product registration card is included with most COGNITRO products, and the software installation process will provide users who have an Internet connection an additional opportunity to register online. The information solicited here is the same as that described above. In order to be able to provide you support, we need you to register your software, especially if you purchased the product from a software vendor and COGNITRO consequently doesn’t yet itself have a record of you as a customer. Some COGNITRO products, during installation, generate a "lock code" that is used by COGNITRO to create a unique license number that links the software to the computer on which it has been installed. Though this code contains information about your computer hardware and is conveyed to COGNITRO, it is encrypted and cannot be used even by COGNITRO to identify you or your computer for any other purpose.

Surveys
COGNITRO occasionally surveys its customers to ask them about products or services they might like COGNITRO to provide or about their satisfaction with products and services we’ve already provided to them. This information is used to improve those offerings and to better meet your needs and expectations. In some cases, the information you provide in such surveys, if you choose to take them, may be linked with the customer information we hold that refers to you. Optional Web site registration COGNITRO offers voluntary registration to our Web site visitors. By registering, you can take advantage of personalization (the ability to select content according to a profile you create for yourself) and reduce the amount of information you provide for repeated transactions. For example, you will not have to provide standard personal contact information (name, e-mail address, phone number, etc.) on each form you complete for downloading files, ordering products, or requesting information or support. During registration, you are required to supply a first name, last name, e-mail address, phone number, and country. You must also select a username and password that will be required for subsequent logins.

Requests for information

COGNITRO includes pre-paid postcards in some professional journals and at our display table at professional conferences that allow people to provide basic contact information and indicate that they’d like additional information on particular aspects COGNITRO products and services. Submitted cards are treated by COGNITRO as protected information just like the information provided when customers purchase products or visitors register on our Web site. Web site usage tracking

General

COGNITRO tracks visitor traffic patterns throughout our sites. We use tracking information to determine which areas of our sites visitors prefer based on traffic to those areas, and to thus improve the overall quality of our site and enhance the visitor's experience. We collect the visitor's domain name, referral data (e.g., the address of the last URL visited prior to clicking through to an COGNITRO Web site), and browser and platform type (e.g., a Netscape 5.x browser on Windows 2000). COGNITRO is interested primarily in aggregate traffic data on our Web site; our needs in this area do not require us to link traffic data to particular people via personally identifiable information they might provide. The only circumstances under which COGNITRO might link traffic data to personal Web registration information involve a direct benefit to customers from this knowledge, and even then, the link is established after the fact, not in real time. For example, COGNITRO Technical Support may occasionally need to revise a posted software patch. When the updated patch is re-posted, we may attempt to identify people (by name, e-mail address, or phone number) who have downloaded the initial patch to inform them that a revision is available. Other than these types of situations, COGNITRO makes no attempt to identify just who is doing what on our Web site.

Cookies

A cookie is a small data file that some Web sites write to your hard drive when you visit them. A cookie file can contain information that the site may use to track the pages your particular computer has visited. The only personal information a cookie can contain, however, is information you supply yourself. A cookie cannot read data off your hard disk or read cookie files created by other sites. COGNITRO uses cookies to track visitor traffic patterns. Depending on your browser’s security settings, you may be prompted when the COGNITRO Web site attempts to write a cookie. You can choose to reject these cookies on a case-by-case basis, or you can adjust your browser’s privacy settings to reject all cookies. In either case, the only cost is the convenience cookies offer. It is not necessary for you to accept cookies to view the COGNITRO Web site.

Web Beacons

Web beacons are small images—often a single pixel and virtually invisible—that may be embedded on a Web page to send information about the traffic to that page to a location other than the one hosting the rest of the page. COGNITRO uses Web beacons as unobtrusive means for collecting the same types of information cookies indicate. And as with cookies on the COGNITRO Web site, it is only COGNITRO that collects this information, not outside parties.


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