PRIVACY POLICY

This Privacy Policy was last updated on 1st May 2017.

Our Policy:

Welcome to the web site (the “Site”) of Cohort, Inc. (“Cohort”, “we”, “us” and/or “our”). This Site is operated by Cohort and has been created to provide information to our Service visitors (“you”, “your”) about our company and our service, which is designed to leverage social graphs to source professional recommendations (“Recommendations”), along with any accompanying mobile applications and related services (together with the Site, the “Services”). This Privacy Policy sets forth Cohort’s policy with respect to information including any personally identified or identifiable data (“Personal Data”) and other information that is collected from visitors to the Site and Services.

Note about Recommendations:

One of the special features of the Services is that we provide our users with Recommendations.  We use the Personal Data and other information you share with us to provide Recommendations to you.  Cohort also learns about you, your skills and your network, from your interactions with Cohort, and from what you share with us.  We use that information to make Recommendations to other Cohort users (for example, if Cohort learns that you know a particular individual, and if someone in your network uses Cohort to seek a Recommendation on someone to introduce them to that individual, we may Recommend you).  Cohort would not otherwise share your Personal Data, except as expressly set forth in this Privacy Policy.

Cohort respects your privacy. This Privacy Policy describes the types of Personal Data we collect, how we use it, with whom we share it, and the choices you can make about our use of this Personal Data. We also describe the measures we take to protect the security of this Personal Data and how you can contact us about our privacy practices.

Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements.

Information We Collect:

By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. 

When you interact with us through the Services, we may collect Personal Data and other information from you, as further described below from various sources including, but not limited to, Twitter and Full Contact:

Personal Data That You Provide Through the Services: We collect Personal Data from you when you voluntarily provide such information, such as when you contact us with inquiries, respond to one of our surveys, register for access to the Services or use certain Services. In this context, we receive your name, email address, Twitter handle, Twitter "tweets", your public Twitter bio, Twitter avatar and certain other publically available data. Wherever Cohort collects Personal Data we make an effort to provide a link to this Privacy Policy. 

In addition, you may choose to submit information directly to Cohort via several channels, including: (i) [on our websites, (ii) in response to marketing or other communications, (iii) through social media, (iv) by signing up for a Cohort product or service, (v) through participation in an offer, program or promotion, or (vi) in connection with an actual or potential business or employment relationship with us.] You may also choose to consent to third parties disclosing information about you to us that those third parties have collected.

The types of Personal Data we may obtain or you may choose to provide to us include:

  • Contact information (such as name, postal or e-mail address, and phone number)
  • Business contact information (such as job title, department and name of organization)
  • Contact information for friends or colleagues
  • Content you provide (such as photographs, articles and comments)
  • Content you make available through social media accounts or memberships with third parties
  • Geo-location data
  • Other information (such as shopping behavior and preferences, language preference, age, date of birth, gender and family status)

By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data to the Services, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of Cohort and the authorized third parties referred to herein located in the United States. 

Other Information: 

Automatically Collected Non-Identifiable Data: When you interact with Cohort through the Services, we receive and store certain personally non-identifiable information automatically. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. Cohort may store such information itself or such information may be included in databases owned and maintained by Cohort affiliates, agents or service providers. The Services may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, and the domain names of our visitors' Internet service providers. It is important to note that no Personal Data is available or used in this process.  

In operating the Services and obtaining your Personal Data, we may use an automated technology called "cookies.". A cookie is a piece of information that the computer that hosts our Services gives to your browser when you access the Services. Our cookies help provide additional functionality to the Services and help us analyze Services usage more accurately. For instance, our Site may set a cookie on your browser that allows you to access the Services without needing to remember and then enter a password more than once during a visit to the Site. The information we collect in this manner may include: [IP address, browser type, operating system, referring URLs and information on actions taken or interaction with our digital assets.] 

In all cases in which we use cookies, we will not collect Personal Data except with your permission. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Service features. 

Aggregated Personal Data: In an ongoing effort to better understand and serve the users of the Services, Cohort often conducts research on its customer demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and Cohort may share this aggregate data with its affiliates, agents and business partners. This aggregate information does not identify you personally. Cohort may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

 

Google Analytics: We may allow third party service providers to use cookies or similar technologies to collect information about your browsing activities over time and across different websites following your use of the Services. For example, we use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the Site and enhance your experience when you use the Service. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners/. 

Our Use of Your Personal Data and Other Information:

Cohort uses the Personal Data you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the Personal Data you provide to answer your question or resolve your problem. 

Also, if you provide We use the Personal Data we collect in order to obtain access to the Services, we will use your Personal Data to provide you with access to the such Sservices and to monitor your use of such Sservices. Cohort and its subsidiaries and affiliates (the “Related Companies”) may also use your Personal Data and other personally non-identifiable information collected through the Services to help us operate, evaluate and improve the content and functionality of the Services, to better understand our users and to improve the Services. Cohort and its affiliates may use this information to provide, administer and communicate to contact you in the future to tell you about services we believe will be of interest to you. If we do so, each marketing communication we send you will contain instructions permitting you to "opt-out" of receiving future marketing communications. In addition, if at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below. We may also use your Personal Data as may be required by applicable laws and regulations or requested by any judicial process or governmental agency having or claiming jurisdiction over Cohort or our Related Companies. 

If Cohort intends on using any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Personal Data is collected.

Our Disclosure of Your Personal Data and Other Information:

Cohort is not in the business of selling your information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth in the “Note about Recommendations Section”, above, and as set forth below: 

Business Transfers: We reserve the right, Aas we develop our business, to transfer your Personal Data we hold in the event of a corporate sale, merger, reorganization, dissolution or similar event relating to all or part of our business ("Reorganization Event"). we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.  Should such a Reorganization Event occur, we will use reasonable efforts to direct the transferee to use Personal Data you have provided to us in a manner that is consistent with our Privacy Policy. Following such a Reorganization Event, you may contact the entity to which we transferred your Personal Data with any inquiries concerning the processing of that information.

Related Companies: In provision of the Services, Wwe may also share your Personal Data with our Related Companies for purposes consistent with, and subject to, this Privacy Policy . 

Agents, Consultants and Related Third Parties:

 Cohort, like many businesses, sometimes hires retains third party vendors or service providers other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments ("Support Services"). When we employ another entity to perform a provide  function of this natureSupport Services, we only provide them with the information that they need to perform their specific function and authorize them to use or disclose your information only as necessary to perform Support Services on our behalf or comply with legal requirements. We require these service providers by contract to safeguard the privacy and security of Personal Data they process on our behalf..

Legal Requirements: Cohort may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Cohort, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) protect against legal liability. 

International Data Transfers: Cohort may transfer the Personal Data we collect about you to the offices and/or servers of Cohort in countries other than the country in which the information was originally collected, including the United States of America. Those countries may not have the same data protection laws as the country in which you initially provided the Personal Data. When we transfer your Personal Data to other countries, we will protect that information as described in this Privacy Policy or as otherwise disclosed to you at the time the data is collected. To offer the Services, we may need to transfer your personal information among several countries, including the United States, where we are headquartered. We comply with applicable legal requirements providing adequate safeguards for the transfer of personal information to countries outside of the European Economic Area ("EEA") or Switzerland.

 

Your Rights and Choices:

You have certain rights regarding the Personal Data and other information we obtain and maintain about you.  We also offer you certain choices about what Personal Data we collect from you, how we use that information, and how we communicate with you.

You can visit the Site without providing any Personal Data. If you choose not to provide any Personal Data, you may not be able to use certain Services. 

Exclusions:

This Privacy Policy does not apply to any Personal Data collected by Cohort other than Personal Data collected from you, through the Services. This Privacy Policy shall not apply to any unsolicited information you provide to Cohort through the Services or through any other means, or that Cohort receives by any other means. This includes, but is not limited to, information posted to any public areas of the Services, such as forums, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and Cohort shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.

Children:

Cohort does not knowingly collect Personal Data from children under the age of 13. If you are under the age of 13, please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Services without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Data to Cohort through the Services, please contact us, and we will endeavor to delete that information from our databases. 

Links to Other Web Sites:  

This Privacy Policy applies only to the Services. The Services may contain links to other web sites not operated or controlled by Cohort (the “Third Party Sites”). The policies and procedures we described here do not apply to the Third Party Sites and we are not responsible for Third Party Sites' content, any use of the Third Party Sites, or the privacy practices of Third Party Sites. The links from the Services do not imply that Cohort endorses or has reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies. 

Integrated Services

One of the special features of the Service is that it allows you to or enables you to, log in to, or via, various online third party services, such as email services like Gmail and social media and social media services such as Twitter One of the special features of the Service is that it allows you to enable or log in to the via various online third party services, such as email services like Gmail and social media and social media services such as Twitter (collectively, “Integrated Service(s)”). By directly integrating these services, we make your online experiences richer and more personalized. To take advantage of this feature, we will ask you to log into or grant us permission via the relevant Integrated Service. When you add an Integrated Services account to the Service or log into the Service using your Integrated Services account, we will collect relevant information necessary to enable the Service to access that Integrated Service and your data contained within that Integrated Service.  As part of such integration, the Integrated Service will provide us with access to certain information that you have provided to the Integrated Service, and we will use, store and disclose such information in accordance with this Privacy Policy.  Please remember that the manner in which Integrated Services use, store and disclose your information is governed by the policies of such third parties, and Cohort shall have no liability or responsibility for the privacy practices or other actions of any Integrated Services that may be enabled within the Service.  If you wish to limit the information that can be shared with Cohort by third parties via the Integrated Services, please refer to the privacy policies of the Integrated Services. 

You may also have the option of posting your Services activities to Integrated Services when you access content through the Services (for example, you may post to Facebook that you performed an activity on the Service); you acknowledge that if you choose to use this feature, your friends, followers and subscribers on any Integrated Services you have enabled will be able to view such activityactivity, according to the privacy policies of the Integrated Services.  Cohort would only post to Integrated Services on your behalf with your consent.

How we Hold and Protect Personal DataSecurity:

The security of your Personal Data is important to us. Cohort takes reasonable steps to protect the Personal Data provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. We maintain administrative, technical and physical safeguards designed to protect the Personal Data you provide or we collect against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. However, no Internet or email transmission is ever fully secure or error free. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any Personal Data to Cohort via the Internet. 

Cohort stores Personal Data only for as long as it is necessary for the fulfillment of the purpose for which the Personal Data was collected, unless otherwise required or authorized by applicable law. We take measures to destroy or permanently de-identify personal information if required by law or if the Personal Data is no longer required for the purpose for which we collected it.

Other Terms and Conditions:

Your access to and use of the Services is subject to the Terms of Service at https://cohort.is/terms

Changes to Cohort’s Privacy Policy:

The Services and our business may change from time to time. As a result, at times it may be necessary for Cohort to make changes to this Privacy Policy. Cohort reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy. 

Access to Information; Contacting Cohort:

To keep your Personal Data accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via the Services.  Upon your request, Cohort will take reasonable efforts to delete all of your Personal Data and non-identifiable information that you have provided to the Services, though Cohort cannot delete any aggregate or otherwise non-indefinable information derived from your Personal Data or from your use of the Services.

To the extent provided by applicable law, you may have the right to obtain confirmation that we hold Personal Data or other information about you, request access to and receive information about the Personal Data we maintain about you, receive copies of the Personal Data we maintain about you, update and correct inaccuracies in your Personal Data, object and withdraw your consent to the processing of your Personal Data and have the information blocked, anonymized or deleted, as appropriate. The right to access Personal Data may be limited in some circumstances by local law requirements. To exercise these rights, please contact us as set forth below.

We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via the Services. Upon your request, Cohort will take reasonable efforts to delete all of your Personal Data and non-identifiable information that you have provided to the Services, though Cohort cannot delete any aggregate or otherwise non-indefinable information derived from your Personal Data or from your use of the Services.

If you provide us with any information or material relating to another person(s), you are responsible for making sure that the sharing with us and our further use as described to you from time to time is in line with applicable laws. 

If we fall short of your expectations in processing your Personal Data or you wish to make a complaint about our privacy practices, you may contact us as set forth below. To assist us in responding to your request, please give full details of the issue. We attempt to review and respond to all complaints within a reasonable time.

Please also feel free to contact us if you have any questions about Cohort’s Privacy Policy or the information practices of the Services.

You may contact us as follows: help@cohort.is

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