Cogstate Privacy Policy

Last updated: May 24, 2018

COGSTATE LTD and its affiliates (collectively, “Cogstate”) respect your right to privacy and are committed to protecting your personal information.

We encourage you to read this Privacy Policy carefully. It describes the practices and procedures that we have established to safeguard and appropriately handle your personal information. Amongst other things, it tells you what information we collect, how we collect it and how we use it and it outlines your rights regarding that information, rights for example to correct, change or to otherwise control your information.

Just as important, in our view, this Privacy Policy and the practices and procedures it describes, affirms our commitment to abide by applicable data privacy and security laws and to good and ethical business practice.

WHAT INFORMATION WE COLLECT AND HOW WE COLLECT IT

Personal information”, as used in this Privacy Policy, is any information relating to an identified or identifiable person. An identifiable person is someone who can be identified, directly or indirectly, by reference to an identifier such as a name, an email address, an identification number, location data, online identifier or to one of more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.

  1. Information you give us

Some visitors to Cogstate’s website may choose to interact with it in ways that require them to provide us with personal information. The amount and type of information that you provide will depend on the nature of the interaction. If you wish to receive our email newsletter or additional information about Cogstate as a company or about its products or services; or register for a webinar or event; or access our presentations, publications, or blog postings; or access our on-demand webinars and podcasts; or use our Cogstate Research web application, we may ask you to provide information tailored to facilitate these requests including: your name and email address, location, company name and job title, telephone number(s), and fax number.  Some of these forms also provide you with optional fields to provide comments, which are not posted publicly and are seen only by Cogstate employees.  You may refuse to provide such personal information, but that may prevent us from being able to provide you with additional information.

Before we first collect your personal information, you will be asked to review this Privacy Policy and affirmatively agree that we may collect and use your personal information in accordance with its terms. To agree, you will have to Opt-In.  You may at any time withdraw your consent to our collection, use or disclosure of your personal information, on reasonable notice, subject to legal or contractual restrictions. We will inform you of the implications of so withdrawing your consent to such collection, use and disclosure.

  1. Information we receive from passive use of our website

Cogstate also collects information about your use of our website through technology such as cookies and web beacons. A “cookie” is a unique numeric code we transfer to your computer so we can keep track of your preferences and recognize you as a return visitor to our Site. A “web beacon” is a piece of code on our website enabling us to monitor things like user activity and site traffic. Cookies allow Cogstate to collect “clickstream” data, which reflects your activities on the website. Cookies do not collect or keep your name or personal information other than the numeric identifier described above. We use the information we collect through the use of cookie technology for business purposes, including operation of the website, such as monitoring traffic, as well as research and product analyses. Before collecting cookie information from your computer, our website will prompt you to either accept or decline the use of cookies. Please note, however, that if you do not accept the use of cookies, certain elements of the website may not work properly.

HOW WE USE YOUR INFORMATION

We may use your personal information:

  • To communicate with you about our company, products or services.
  • To improve our products or services, including our website.
  • To maintain and administer our website.
  • To evaluate the quality of our products and services.
  • To comply with our legal, regulatory, compliance or auditing obligations.

We will only collect and use personal information that you choose to give us, that is necessary for our legitimate business purposes, that is required by law or regulation or as otherwise described in this Privacy Policy.

We will retain your personal information only for as long as reasonably necessary to carry out the purposes for which it was collected.

HOW AND WHY WE MIGHT SHARE YOUR INFORMATION

Cogstate will not disclose your personal information without your consent to do so, except:

  • To carry out the purposes for which you have provided it to us;
  • In the context of a sale, amalgamation, re-organization, transfer or financing of parts or some or all of Cogstate’s business; or
  • For purposes of research and development where your personal information combined with all or some of the personal information of other users and such aggregated data no longer contains personal information.

In any such case, Cogstate will require recipients to comply with the terms of this Privacy Policy and all applicable data privacy and security laws.

In the unlikely event we discover that a recipient is using personal information in way that conflicts with this Privacy Policy, we will take all reasonable steps to stop them.

We do not permit third-party advertisers to display their advertisements on our website.

TRANSFERRING INFORMATION

Under some circumstances, we may need to transfer personal information from one jurisdiction to another, including to jurisdictions where the laws provide different protection than the jurisdiction from which the information was derived. In any such case, we will take appropriate measures to ensure that personal information is transferred, processed and protected in accordance with this Privacy Policy and all applicable data privacy and security laws.

CHILDREN

Cogstate’s website is intended for users eighteen (18) or older. It is not in any way designed to attract children. If we discover that a person under the age of eighteen (18) has submitted personal information to our website, or that someone has inappropriately done so on their behalf, we will delete such information from our databases as soon as practicable and in accordance with applicable law.

TECHNICAL, PHYSICAL AND ADMINISTRATIVE SECURITY

We have implemented commercially reasonable security safeguards to protect your personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. Methods of protection include: physical measures (e.g., locked filing cabinets and restricted access to offices); organizational measures (e.g., security clearances and limiting access on a “need-to-know” basis); and technological measures (e.g., the use of complex passwords and encryption of data at rest and in transit).

YOUR RIGHTS AND CHOICES

  1. Access and Correction

You may at any time challenge the accuracy and completeness of your personal information and have it amended or corrected as appropriate. In any such case, Cogstate may request that you provide identifying information sufficient to verify your identity and ownership of the information. Any such identifying information shall be used only for this purpose.

  1. Receipt or transfer

You may at any time request to receive one copy of your personal information and to have your personal information transferred to a third-party. In any such case, we will, where technically feasible, provide it in a structured, commonly used and machine-readable format.

Please note that this right of portability applies only in limited circumstances, such as:  where we are processing personal data on the basis of your consent or pursuant to our contractual agreements with you, and the processing is carried out by automated means.

  1. Deletion

You have the right to request that Cogstate permanently delete your personal information when:

  • we no longer need your data for the purposes for which it was collected;
  • we have been processing the particular data based only on your consent, you withdraw your consent, and there is no other legal ground for us to continue processing;
  • you successfully object to the processing of certain data (see “Objection” below);
  • the data has been unlawfully processed; or
  • erasure is required by law.

 

This right will not apply where continued processing of your personal information is necessary for:

  • the exercise of the right of freedom of expression and information;
  • compliance with applicable law;
  • performance of a task carried out in the public interest or the exercise of official authority vested in Cogstate;
  • for reasons of public health;
  • certain types of archiving that is in the public interest, scientific or historical research or statistical purposes; or
  • the establishment, exercise or defense of legal claims.

Although Cogstate may remove most personal information, such as contact information (address, phone number, etc.), we cannot remove certain records which we are bound to keep by law or by codes of conduct or other authority.

  1. Objection and Restriction

You may at any time request that Cogstate cease or restrict certain processing of your personal information.  If you are in any way unhappy with our collection or use of your personal information or even the terms of this Privacy Policy, we hope that you will contact us as described below so that we can address your concerns. If however you would like to lodge a complaint, you have the right to do so by contacting your local supervisory authority for further assistance and information.

HOW DO I EXERCISE THESE RIGHTS AND OPTIONS?

If you wish to take any of the actions described above, please do so by contacting us as described below.  We will attend to your request promptly and will respond within a reasonable time.

CONTACT US

Should you have any questions or concerns regarding this Privacy Policy or our collection or use of your personal information, please contact Cogstate’s Chief Privacy Officer via email at privacy@cogstate.com privacy@cogstate.com; via telephone at +1.203.773.5010; or via mail at:

Cogstate Inc
Attention Chief Privacy Officer
195 Church Street, 4th Floor
New Haven, CT 06510
USA

CHANGING OUR PRIVACY POLICY

We will only use personally identifying information in the manner described in the Privacy Policy in effect when the information was collected from you.

We reserve the right, however, to change the terms of this Privacy Policy at any time by posting revisions to the website. In any such case, we will take reasonable measures to obtain your consent.