Privacy and Personal Information Protection Policy

Coginov Privacy Statements

Coginov (“Coginov,” “we,” “us,” “our,” or the “Company”) is committed to protecting the privacy of individuals who visit the Company’s Web sites (“Visitors”), individuals who register to use the Services as defined below (“Customers”), and individuals who register to attend the Company’s corporate events (“Attendees”). This Privacy Statement describes Coginov’s privacy practices in relation to the use of the Company’s Web sites and the related applications, services, and programs offered by Coginov (collectively, the “Services”), as well as individuals’ choices regarding use, access, and correction of personal information. Coginov’s services comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) regarding the collection, use, and retention of personal information. If you have questions or complaints regarding Coginov’s Privacy Statement or associated practices, please see contact information below.

1 – Web sites covered

This Privacy Statement covers the information practices, including how the Company collects, uses, shares, and secures the personal information you provide, of Web sites that link to this Privacy Statement (collectively referred to as “Coginov’s Web sites” or “the Company’s Web sites”). Coginov’s Web sites may contain links to other Web sites. The information practices or the content of such other Web sites is governed by the privacy statements of such other Web sites. The Company encourages you to review the privacy statements of other Web sites to understand their information practices.

2 – Information collected

When expressing an interest in obtaining additional information about the Services or registering to use the Web sites or other Services, or registering for an event, Coginov requires you to provide the Company with personal contact information, such as name, company name, address, phone number, and email address (“Required Contact Information”). When purchasing the Services or registering for an event, Coginov may also require you to provide the Company with financial qualification and billing information, such as billing name and address, credit card number, and the number of employees within the organization that will be using the Services (“Billing Information”). Coginov may also ask you to provide additional information, such as company annual revenues, number of employees, or industry (“Optional Information”). When Visitors apply for a job with the Company, Coginov may also require you to submit additional personal information as well as a resume or curriculum vitae (“Applicant Information”). Required Contact Information, Billing Information, Applicant Information, Optional Information, and any other information you submit to Coginov to or through the Services are referred to collectively as “Data.” As you navigate the Company’s Web sites, Coginov may also collect information with commonly used information-gathering tools, such as cookies and Web beacons (“Web Site Navigational Information”). Web Site Navigational Information includes standard information from your Web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on the Company’s Web sites (such as the Web pages viewed, and the links clicked). Through our “import contacts” feature option, we may also collect information such as the name, company name, address, phone number or email address of contacts that you choose to share with us. When you provide us with personal information about your contacts, we will only use this information for the specific reason for which it is provided, such as to add new records to your Coginov account.

Children

Our websites and apps deliver business-related content and are specifically aimed at and designed for use by adults. We do not knowingly solicit or collect information from or about individuals under the age of 18 years.

3 – Use of information collected

The Company uses Data about Coginov Customers to perform the services requested. For example, if you fill out a “Contact Us” Web form, the Company will use the information provided to contact you about your interest in the Services. The Company also uses Data about Coginov Attendees to plan and host online forums and social networks in which event Attendees may participate, and to populate online profiles for Attendees on the Company’s Web sites. Additional information on the Company’s privacy practices with respect to Data about Coginov Attendees may be found in additional privacy statements on the event Web sites. The Company may also use Data about Coginov Customers and Attendees for marketing purposes. For example, the Company may use information you provide to contact you to further discuss your interest in the Services and to send you information regarding the Company, its affiliates, and its partners, such as information about promotions or events. Coginov may also receive information about Customers and Attendees from other sources, including third parties from whom we have purchased data, and combine this information with Data we already have about you. This helps us to update, expand and analyze our records, identify new customers, and create more tailored advertising to provide products and services that may be of interest to you.

4 – Web Site Navigational Information

Cookies, Web Beacons, and IP Addresses

Coginov uses commonly used information-gathering tools, such as cookies and Web beacons, to collect information as you navigate the Company’s Web sites (“Web Site Navigational Information”). As described more fully below, we and our partners use these cookies or similar technologies to analyze trends, administer Web sites and Services, track users’ movements around our Web sites and Services, serve targeted advertisements and gather demographic information about our user base. This section describes the types of Web Site Navigational Information used on the Company’s Web sites and Services, and how this information may be used.

Regarding Cookies specifically

Coginov uses cookies to make interactions with the Company’s Web sites easy and meaningful. When you visit one of the Company’s Web sites, Coginov’s servers send a cookie to your computer or device. Standing alone, cookies do not personally identify you; they merely recognize your Web browser. Unless you choose to identify yourself to Coginov, either by responding to a promotional offer, opening an account, or filling out a Web form (such as a “Request a Demo” Web form) or have previously identified yourself to Coginov, you remain anonymous to the Company. Coginov uses cookies that are session-based and persistent-based. Session cookies exist only during one session. They disappear from your computer or device when you close your browser software or turn off your computer. Persistent cookies remain on your computer or device after you close your browser or turn off your computer. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our Web sites or Services.

The following sets out how Coginov.com uses different categories of cookies and your options for managing cookies’ settings:

Web Beacons

Coginov may use Web beacons alone or in conjunction with cookies to compile information about Customers and Visitors’ usage of the Company’s Web sites and interaction with emails from the Company. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular Web site or Service tied to the Web beacon, and a description of a Web site or Service tied to the Web beacon. For example, Coginov may place Web beacons in marketing emails that notify the Company when you click on a link in the email that directs you to one of the Company’s Web sites. Coginov uses Web beacons to operate and improve the Company’s Web sites, Services and email communications.

Log Files, IP Addresses, URLs, and Other Data

As is true of most Web sites, we gather certain information automatically to analyze trends in the aggregate and administer our Web sites and Services. This information may include your Internet Protocol (IP) address (or the proxy server you use to access the World Wide Web), device and application identification numbers, your location, your browser type, your Internet service provider and/or mobile carrier, the pages, and files you viewed, your searches, your operating system and system configuration information, and date/time stamps associated with your usage. Due to Internet communications standards, when you visit or use the Company’s Websites and Services, we automatically receive the URL of the website from which you came and the website to which you go when you leave our Website. This information is used to analyze overall trends, to help us improve our Websites and Services, to track and aggregate non-personal information, and to provide the Websites and Services. For example, Coginov uses IP addresses to monitor the regions from which Customers and Visitors navigate the Company’s Web sites. Coginov also collects IP addresses from Customers when they log into the Services as part of the Company’s “Identity Confirmation” and “IP Range Restrictions” security features.

Social Media Features and Single Sign-on

The Company’s Web sites may use social media features, such as the Facebook “like” button (“Social Media Features”). These features may collect your IP address and which page you are visiting on the Company’s Web site and may set a cookie to enable the feature to function properly. You may be given the option by such Social Media Features to post information about your activities on the Company’s Web site to a profile page of yours that is provided by a thirdparty social media network in order to share with others within your network. Social Media Features are either hosted by a third party or hosted directly on the Company’s Web site. Your interactions with these features are governed by the privacy policy of the company providing the relevant Social Media Features.

Do Not Track

Currently, various browsers — including Internet Explorer, Firefox, and Safari — offer a “do not track” or “DNT” option that relies on a technology known as a DNT header, which sends a signal to Web sites’ visited by the user about the user’s browser DNT preference setting. Coginov does not currently commit to responding to browsers’ DNT signals with respect to the Company’s Web sites, in part, because no common industry standard for DNT has been adopted by industry groups, technology companies or regulators, including no consistent standard of interpreting user intent. Coginov takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.

5 – Public forums, refer a contact, and customer testimonials

Coginov may provide bulletin boards, blogs, or chat rooms on the Company’s Web sites. Any personal information you choose to submit in such a forum may be read, collected, or used by others who visit these forums, and may be used to send you unsolicited messages. Coginov is not responsible for the personal information you choose to submit in these forums.

Coginov may post a list of Customers and testimonials on the Company’s Web sites that contain information such as Customer names and titles. Coginov obtains the consent of each Customer prior to posting any information on such a list or posting testimonials.

6 – Sharing of information collected

Service Providers

Coginov may share Data about Coginov Visitors, Customers and Attendees with the Company’s contracted service providers so that these service providers can provide services on our behalf. These service providers are authorized to use your personal information only as necessary to provide the requested services to us. Without limiting the foregoing, Coginov may also share Data about Coginov Visitors, Customers and Attendees with the Company’s service providers to ensure the quality of information provided, and with third–party social networking and media Web sites, such as Facebook, for marketing and advertising on those Web sites. Unless described in this Privacy Statement, Coginov does not share, sell, rent, or trade any information with third parties for their promotional purposes.

Business Partners

From time to time, Coginov may partner with other companies to jointly offer products, services, or programs (such as webinars or downloadable content). If you purchase, specifically express interest in, or register for a jointly offered product, service, or program from or through Coginov, the Company may share Data about Coginov Customers collected in connection with your purchase or expression of interest with our partner(s). Coginov does not control our business partners’ use of the Data about Coginov Customers that we collect, and their use of the information will be in accordance with their own privacy policies. If you do not wish for your information to be shared in this manner, you may opt not to purchase or specifically express interest in a jointly offered product or service.

Coginov does not share Data about Coginov Attendees with business partners unless you specifically opt into such sharing via an event registration form. If you do not wish for your information to be shared in this manner, you may choose not to opt in via event registration forms. If you choose to share your information with business partners in the manners described above, your information will be subject to the business partners’ respective privacy statements.

Third Parties

Section 4 of this Privacy Statement, Web Site Navigational Information, specifically addresses the information we or third parties collect through cookies and web beacons, and how you can control cookies through your Web browsers. We may also disclose your personal information to any third party without your prior consent.

Billing

Coginov uses a third-party service provider to manage credit card processing. This service provider is not permitted to store, retain, or use Billing Information except for the sole purpose of credit card processing on the Company’s behalf.

Compelled Disclosure

Coginov reserves the right to use or disclose information provided if required by law or if the Company reasonably believes that use or disclosure is necessary to protect the Company’s rights and/or to comply with a judicial proceeding, court order, or legal process.

7 – International transfer of information collected

The Company primarily stores Data about Coginov Customers and Data about Coginov Attendees in Canada. To facilitate Coginov’s global operations, the Company may transfer and access such information from around the world, including from other countries in which the Company has operations. This Privacy Statement shall apply even if Coginov transfers Data about Coginov Customers or Data about Coginov Attendees to other countries.

8 – Communications preferences

Coginov offers Visitors, Customers, and Attendees who provide contact information a means to choose how the Company uses the information provided. You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of the Company’s marketing emails.

9 – Correcting and updating your information

Coginov may retain your information for a period consistent with the original purpose of collection. For instance, we may retain your information during the time in which you have an account to use our Web sites or Services and for a reasonable period afterward. We also may retain your information during the period needed for Coginov to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes, and enforce our agreements.

You may request to review, correct, delete, or otherwise modify any of the personal information that you have previously provided to us through the Company’s Web sites and Services. If you have registered for an account with Coginov, you may generally update your user settings, profile, organization’s settings, or event registration by logging into the applicable Website or Service with your username and password and editing your settings or profile. To update your billing information, discontinue your account, and/or request return or deletion of Your Data associated with your account, please contact your account representative or the customer service team for the applicable Service (including Insights, Talent Match & Digiseer). For other requests to access, correct, modify, or delete Your Data, please review the “Contacting Us” section below. Requests to access, change, or delete your information will be addressed within a reasonable timeframe. If you are an employee of a Coginov customer, you may also wish to contact your company’s system administrator for assistance in correcting or updating your information.

10 – Customer Data

Coginov’s Customers may electronically submit data or information to the Services for hosting and processing purposes (“Customer Data”). Coginov will not review, share, distribute, or reference any such Customer Data except as provided in Coginov’s Master Subscription Agreement, or as may be required by law. In accordance with Coginov’s Master Subscription Agreement, Coginov may access Customer Data only for the purpose of providing the Services or preventing or addressing service or technical problems or as may be required by law.

Coginov acknowledges that you have the right to access your personal information. If personal information pertaining to you as an individual has been submitted to us by a Coginov customer and you wish to exercise any rights you may have to access, correct, amend, or delete such data, please inquire with our customer directly. Because Coginov personnel have limited ability to access data our customers submit to our Services, if you wish to make your request directly to Coginov, please provide the name of the Coginov customer who submitted your data to our Services. We will refer your request to that customer and will support them as needed in responding to your request within a reasonable timeframe.

11 – Security

Coginov uses robust security measures to protect Data about Coginov Customers and Data about Coginov Attendees. Because the Company uses the Services to maintain Data about Coginov Customers and Data about Coginov Attendees, this information, which is stored in the Services, is secured.

12 – Mobile applications

Without limiting the generality of this Privacy Statement, in addition to information gathered through its Web sites or submitted to its Services, Coginov may obtain information through applications (“Mobile Applications”) that Customers or their authorized individuals (“Users”) download to, and run on, their mobile devices (“Devices”). Mobile Applications provided by Coginov may obtain information from, or access data stored on, Users’ Devices to provide services related to the relevant Mobile Application. For example, a Mobile Application may: access a camera on a User’s Device to enable the User to upload photographs to the Services; access the call history on a User’s Device to enable the User to upload that information to the Services; access calendar information on a User’s Device to enable the User to match meeting attendees with contacts submitted by the User to the Services; access the geographic location of a User’s Device to enable the User to identify contacts submitted by the User the Services who are nearby; or access contact information on a User’s Device to enable the User to sync contact information between the information that is stored on the User’s Device and the information that is submitted to the Services. Information obtained to provide Mobile Application services may include information obtained in preparation for anticipated updates to those services. Mobile Applications may transmit information to and from Devices to provide the Mobile Application services.

Mobile Applications may provide Coginov with information related to Users’ use of the Mobile Application services, information regarding Users’ computer systems, and information regarding Users’ interaction with Mobile Applications, which Coginov may use to provide and improve the Mobile Application services. For example, all actions taken in a Mobile Application may be logged, along with associated information (such as the time of day when each action was taken). Coginov may also share anonymous data about these actions with third party providers of analytics services. In addition, if a User downloads a Coginov Mobile Application after clicking on a thirdparty mobile advertisement for the Mobile Application or for Coginov, the third-party advertiser may provide Coginov with certain information, such as the User’s Device identification information, which Coginov may use to track the performance of its advertising campaigns.

The Mobile Application’s access to information through a User’s Device does not cause that information to be « Customer Data » under Coginov’s Master Subscription Agreement with the Customer or under this Privacy Statement, except as follows: To the extent that a User uses a Mobile Application to submit electronic data and information to a Customer account on our Services pursuant to the Customer’s Master Subscription Agreement with Coginov (or a similar agreement that governs the Customer’s subscription(s) to Coginov’s Services), that information constitutes “Customer Data” as defined in such agreement, and the provisions of that agreement with respect to privacy and security of such data will apply.

13 – Changes to this Privacy Statement

Coginov reserves the right to change this Privacy Statement. Coginov will provide notification of the material changes to this Privacy Statement through the Company’s Web sites at least thirty (30) business days prior to the change taking effect.

Contacting us

Questions regarding this Privacy Statement or the information practices of the Company’s Web sites and Services should be directed to Coginov Privacy by mailing us at: 1000 Rue de Sérigny, Longueuil, QC J4K 5B1 or at info@coginov.com

CONTACT

If you would like to review, correct or update your personal information, opt-out of its collection, use and/or disclosure, access or correct any personal information in our possession, or if you have any questions or comments about this Website Privacy Policy, please contact us at info@coginov.com

PRIVACY OFFICER

The person responsible for the protection of personal information at Coginov is Mr. Alkis Papadopoullos, CEO. He can be reached at rprp@coginov.com