1. 1. Acceptance of Privacy Policy
   1. 1.1 Cogi-Member Relationship & Intro. Cogi, Inc. ("Cogi") values the privacy of its Members ("you", "your", or "Member"). This Privacy Policy has been developed to disclose how Cogi gathers, uses and protects our Members' personal information. This policy applies to all websites, products and services offered by Cogi. By agreeing to the Cogi Terms of Service Member also agrees to the Cogi Privacy Policy.
2. 2. Collecting Personal Information
   1. 2.1 Registration Information. When Member signs up for a Cogi account, Member must provide certain personal information, such as: name, email address, phone numbers, payment information, and an account password. Additionally, Member may be asked to provide various personal details which would be used solely for internal Cogi analyses. This requested information may include, but not be limited to, date of birth, general demographic and employment information.
   2. 2.2 Account Activity. Once Member's account has been established and is in use, Cogi may record information about your usage, such as: frequency of access to account, frequency of conducting calls using Cogi, the size of Member-generated content/storage capacity, the size of your contact list, the frequency of content sharing, and other activity in conjunction with Member's use of Cogi.
   3. 2.3 Computer Browser. Additional information collected by Cogi may include information provided by Member's computer browser as a result of cookies placed by Cogi. (See Section 5: Cookies)
   4. 2.4 Purpose of Information. All information submitted by Member and gathered by Cogi helps Cogi to modify its website, services and products to better meet the needs of our Members. This information also ensures that Cogi has a detailed understanding of our Members' demographics and account usage, which contributes to our customer acquisition and marketing strategies, as well as our product research and development.
   5. 2.5 Information of Others. If Member provides the personal information of a friend to Cogi, Member warrants that you are authorized to provide such information. (See Section 6: Tell A Friend)
   6. 2.6 Accuracy of Information. Member ensures that information submitted to Cogi is current and accurate. Cogi provides Member with access to personal information via their account, enabling Member to update such information as needed.
3. 3. Use of Personal Information
   1. 3.1 Use of Personally Identifiable Information. Cogi never shares Members' personally identifiable information with third parties, with the following exceptions:
      • If Cogi has received opt-in consent from the Member;
      • If Cogi believes it is necessary to respond to legal action or an enforceable governmental request;
      • To enforce Terms of Service;
      • To address fraud, security or technical issues; or to protect the rights, property or security of Cogi, its members and the public;
      • As part of a contract with a co-branded partner (see Section 8: Partners);
      • For billing purposes, which may be conducted through a third-party;
      • It may be used to carry out a credit check, if necessary for billing purposes. In this case, your personally identifiable information will be disclosed to a third-party credit agency or financial institution for the sole purpose of this credit check;
      • In connection with a corporate merger, acquisition or other corporate reorganization.
   2. 3.2 Use of Non-Personally Identifiable Information. The Members' non-personally identifiable information may be used in the following ways:
      • To communicate with our Members. Opt-out options are made available;
      • To modify Cogi's website, services and products to better meet the needs of our Members;
      • To develop a detailed understanding of our Members' demographics and account usage for service/product research and development;
      • To analyze our business, customer service, advertising and marketing strategies;
      • Demographic information may be provided to our advertisers to determine placement;
      • It may be provided to all Cogi offices, subsidiaries, affiliates or other trusted third-parties who Cogi has contracted with in order to provide Cogi services or process Member information. These parties are required to do so in a confidential and secure manner in accordance with this Privacy Policy and the Cogi Terms of Service;
      • Communication between Member and Cogi may be used as a testimonial or for other marketing purposes.
      • In this case, your first name, last initial, city and state may be used publicly. No other personal information will be used without your consent.
   3. 3.3 Renting or Selling Information. Cogi does not rent or sell its Member information, whether personally or non-personally identifiable.
   4. 3.4 Opt-In Policy. If Cogi wishes to use or disclose your personal information in a manner not laid out in this policy, you will be provided with the opportunity to opt-in (give permission).
4. 4. Content Handling
   1. 4.1 Cogi Access To Member Information & Accounts. Access to personal information, Members' accounts, and Member-created content (i.e. audio recordings, transcripts of Cogi phone calls, meetings, and notes about the calls) is restricted to a limited number of Cogi employees, contractors and agents who require access in order to conduct Cogi business. These Cogi team members operate under strict confidentiality policies and may be subject to discipline, termination and even criminal prosecution if they digress from Cogi policies.
   2. 4.2 Purpose of Access to Member Accounts. Cogi will access Members' Accounts for the purpose of determining causes and solutions to technical issues, and to conduct speech research in relation to the continued development of our state of the art speech recognition methods. Cogi does not warrant that Member-created content will never be seen or heard by Cogi representatives. Cogi may be required by a governmental or legal request to access and/or disclose your personal information and the content of your communications in the case of a search warrant, subpoena, court order, or other legal process.
   3. 4.3 Cogi Facilities Handling Information. Members' personal information may be stored, processed, accessed and handled in a Cogi facility or a facility of its agents in the United States. All facilities are required to comply with this Privacy Policy and the Cogi Terms of Service.
   4. 4.4 Data Security. Cogi works hard to consistently provide a high level of security to protect Members' personal information, accounts, and content. This security involves limiting access to key representatives, firewalls, encryption of communication and data transmissions, and other physical security procedures at all Cogi data centers, such as intrusion detection systems. These security measures are constantly monitored and reviewed to protect Member data.
   5. 4.5 Consent To Record Calls. In order to record calls using Cogi, Member is required to request and receive consent from all involved parties for each individual call made. It is the Member's responsibility to ensure that consent is received in accordance with all applicable laws. Each state has its own regulations regarding obtaining consent – some require consent from both parties, some from only one party. View a listing of state requirements.
   6. 4.6 Capturing Content. When using Cogi to capture calls, Member has full control over the moments during the call that will be captured in audio file format. Member also has full control over the decision to transcribe a call or keep it as an audio file only. This can be done in the "Settings" section of your account.
   7. 4.7 Storing Content. Member has the option of deleting any audio files or transcribed content within their account. Once deleted, said content may remain archived for back-up purposes within the Cogi system for a period of time. Cogi retains no liability in the case that content becomes lost due to deletion by Member.
   8. 4.8 Sharing Content. Member may share audio files or transcribed content with others by means of using the "Share This Call" section in your account. Clicking the "Add" button gives Cogi permission to send a link to the content via email to contacts designated by you. This feature, however, does not prevent that contact from copying and pasting your transcriptions or otherwise manually recording them.
5. 5. Cookies
   1. 5.1 Storing Cookies. When visiting Cogi's website or logging into your Cogi account, cookies may be stored on your computer. These cookies allow us to recognize your computer so we can improve your user experience, and remember your login/password information and other user preferences. Cogi may use cookies to deliver content to Member coinciding with personal interests, to track ad click rates and impressions, and they may be analyzed to help us improve your experience. 5.2 Disabling Cookies. Member may set your browser to disable cookies. Please keep in mind, however, that if you disable cookies, you may affect your experience when using our services.
6. 6. Payment Information
   1. 6.1 Payment Processing. Member may be required to provide a credit card or other form of payment in order to keep your account in good standing. This payment information will only be provided to the company or companies that Cogi is contracted with to process payments, and will never be shared with an unrelated third party. Cogi will hold your payment information securely and confidentially, and access to such information will be limited to Cogi team members who work with payment processing companies.
7. 7. Partners
   1. 7.1 Co-Branded Partnerships. Cogi may become involved in a co-branded partnership with another service or application provider. As a result co-branded services or applications may be offered to Cogi Members. Upon accepting use of these co-branded offers, Member gives permission to Cogi to share their demographic information with the co-branded partner for use in developing marketing and advertising strategies.
8. 8. Third-Party Websites
   1. 8.1 Third-Party Websites. Cogi may provide Members with links to third-party websites. Cogi does not have control over such websites, their privacy policies, or the manner in which they gather and handle your personal information. They may also place cookies or other files on your computer. It is Member's responsibility to read all terms of service and privacy policies related to third-party websites.
9. 9. Changes to Privacy Policy
   1. 9.1 Changes to Privacy Policy. Cogi reserves the right to make changes to this Privacy Policy at any time at its own discretion. The new version of the Privacy Policy will be posted to the Cogi website. If Member disagrees with revisions to the Privacy Policy, Member reserves the right to cancel their Cogi account at any time. Continued use of the Cogi website and/or any Cogi products and services after a revised Privacy Policy has been posted will mean that Member has accepted the changes made.
10. 10. Contact
    1. 10.1. Any questions or comments about the Cogi Privacy Policy should be directed to support@cogi.com.

Last Updated: November 12, 2008