Privacy Policy

This privacy notice for Cognition Compound UG (haftungsbeschränkt) (“we”, “us”, or “our”) describes how and why we may collect, store, use, and/or share (“process”) your information when you use our services (“Services”), such as when you:

Visit our website at https://resufit.com, our web application at https://app.resufit.com, or any other website or application of ours that links to this privacy notice
Use ResuFit to build resumes, cover letters, and practice interviews
Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at legal@cognitioncompound.com.

Summary of Key Points

This summary provides key points from our privacy notice, but you can find out more details about any of these topics in the relevant section below.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. See What Information Do We Collect?
Do we process any sensitive personal information? We do not intentionally request sensitive personal information. However, the resume, profile, and interview content you choose to submit may contain sensitive information, which is processed by our AI providers to generate content. See How We Use AI.
Do we collect any information from third parties? If you register or log in using a social account (Google, LinkedIn, or Apple), we receive limited profile information from that provider. See How Do We Handle Your Social Logins?
How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, generate AI-powered resume and interview content, for security and fraud prevention, and to comply with law. See How Do We Process Your Information?
In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. See When and With Whom Do We Share Your Personal Information?
How do we keep your information safe? We have organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure. See How Do We Keep Your Information Safe?
What are your rights? Depending on where you are located geographically, applicable privacy law may give you certain rights regarding your personal information. See What Are Your Privacy Rights?
How do you exercise your rights? The easiest way to exercise your rights is by contacting us at legal@cognitioncompound.com. We will consider and act upon any request in accordance with applicable data protection laws.

1. What Information Do We Collect?

Personal information you disclose to us

In short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

names
phone numbers
email addresses
mailing addresses
job titles
usernames
passwords
contact preferences
contact or authentication data
billing addresses

Resume, Profile, and Job-Application Data. To generate resumes, cover letters, and interview questions, we process the content you submit for that purpose, including:

resume and CV content (work history, education, skills, contact details)
career profile information you enter or import
job postings or job descriptions you provide for tailoring generated content
your responses during interview practice sessions

See How We Use AI below for how this data is processed by third-party AI providers.

Sensitive Information. We do not intentionally collect sensitive information. However, the resume, profile, and interview content you choose to submit may contain sensitive information (for example, details that reveal health, or racial or ethnic origin). This content is processed by our AI providers to generate resumes, cover letters, and interview questions. Please do not submit sensitive information you do not want processed in this way.

Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number and the security code associated with your payment instrument. All payment data is handled and stored by Stripe. You may find their privacy notice here: https://stripe.com/privacy.

Social Media Login Data. We may provide you with the option to register with us using your existing social media or third-party account details, like your Google, LinkedIn, or Apple account. If you choose to register in this way, we will collect certain profile information about you from that provider, as described in the section called “How Do We Handle Your Social Logins?” below.

Application Data. If you use our application(s), we may also collect the following information if you choose to provide us with access or permission:

Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device’s settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Policy: Cookie Policy.

The information we collect includes:

Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports, and hardware settings).
Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, internet service provider and/or mobile carrier, operating system, and system configuration information.
Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

2. How Do We Process Your Information?

In short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
To deliver and facilitate delivery of services to the user, including generating resumes, cover letters, and interview questions using your provided content. We may process your information to provide you with the requested service.
To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
To fulfil and manage your orders. We may process your information to fulfil and manage your orders, payments, returns, and exchanges made through the Services.
To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see “What Are Your Privacy Rights?” below.
To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

3. How We Use AI

In short: We use third-party AI models from Anthropic and OpenAI to generate resumes, cover letters, and interview questions from the content you provide. Do not submit data you do not want processed by these providers.

ResuFit’s core function is generating resumes, cover letters, and interview questions using artificial intelligence. To do this, when you use these features we send the content you submit — such as your resume text, career profile, and any job posting or job description you provide — to large language models operated by:

Anthropic (Claude models)
OpenAI (GPT models)

These providers process the data solely to return generated output back to ResuFit; we do not permit them to use your data to train their own general-purpose models under our commercial agreements with them. Each provider processes data under its own data processing terms and may store your requests and outputs briefly for abuse monitoring and service operation, consistent with their published policies.

You should not submit personal information you do not want processed in this way. This includes information about third parties (such as references or former colleagues) unless you have their permission to include it, and any sensitive information (such as health data, government identifiers, or protected characteristics) that is not necessary for generating your resume or interview content.

AI-generated content may contain inaccuracies. You are responsible for reviewing and verifying any resume, cover letter, or interview material before you rely on or submit it.

4. What Legal Bases Do We Rely On To Process Your Personal Information?

In short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases:

Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. See “Withdrawing your consent” below.
Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services (such as generating resumes and interview content) or at your request prior to entering into a contract with you.
Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms, for example to:
- Send users information about special offers and discounts on our products and services
- Analyse how our Services are used so we can improve them to engage and retain users
- Support our marketing activities
- Diagnose problems and/or prevent fraudulent activities
- Understand how our users use our products and services so we can improve user experience
Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

In legal terms, we are generally the “data controller” under European data protection laws of the personal information described in this privacy notice, since we determine the means and/or purposes of the data processing we perform. This privacy notice does not apply to personal information we process as a “data processor” on behalf of our customers. In those situations, the customer we provide services to is the “data controller” responsible for your personal information, and we merely process it on their behalf in accordance with their instructions.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e. express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e. implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
For investigations and fraud detection and prevention
For business transactions provided certain conditions are met
If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
For identifying injured, ill, or deceased persons and communicating with next of kin
If we have reasonable grounds to believe an individual has been, is, or may be the victim of financial abuse
If it is reasonable to expect that collection with consent would compromise the availability or accuracy of the information, and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
If disclosure is required to comply with a subpoena, warrant, court order, or rules of court relating to the production of records
If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
If the collection is solely for journalistic, artistic, or literary purposes
If the information is publicly available and is specified by the regulations

In short: We may share information in specific situations described in this section and/or with the following third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (“third parties”) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it, and they will not share your personal information with any organisation apart from us.

The subprocessors we currently use are:

Processor	Purpose	Data region
Anthropic	AI generation of resumes, cover letters, and interview questions	United States (Standard Contractual Clauses)
OpenAI	AI generation of resumes, cover letters, and interview questions	United States (Standard Contractual Clauses)
Stripe	Payment processing and billing	United States / European Union (Standard Contractual Clauses)
PostHog	Product analytics	European Union (EU Cloud)
Microsoft Clarity	Product analytics (session behaviour, heatmaps)	United States / European Union
Google Analytics / Google Ads	Marketing analytics and advertising	United States (Standard Contractual Clauses)
Meta (Facebook) Pixel	Marketing analytics and advertising	United States (Standard Contractual Clauses)
Sentry	Error and performance monitoring	United States (Standard Contractual Clauses)
Brevo	Transactional email and live chat	European Union (France)
WonderPush	Push notifications	European Union
Google	Social sign-in (OAuth)	United States (Standard Contractual Clauses)
LinkedIn	Social sign-in (OAuth)	United States (Standard Contractual Clauses)
Apple	Social sign-in (“Sign in with Apple”)	United States (Standard Contractual Clauses)
Cloudflare	Content delivery network, DDoS protection, and security	Global network (Standard Contractual Clauses where applicable)
Hetzner	Application hosting and infrastructure	Germany (European Union)

We also may need to share your personal information in the following situations:

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

6. Do We Use Cookies and Other Tracking Technologies?

In short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements and tailor advertisements to your interests. These third parties use their technology to provide advertising about products and services tailored to your interests, which may appear either on our Services or on other websites.

To the extent these online tracking technologies are deemed to be a “sale”/“sharing” (which includes targeted advertising, as defined under applicable laws) under applicable US state laws, you can opt out as described below under “Do United States Residents Have Specific Privacy Rights?”

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy: Cookie Policy.

Google Analytics

We may share your information with Google Analytics to track and analyse the use of the Services. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. You can opt out of Google Analytics Advertising Features through Ads Settings. Other opt-out means include http://optout.networkadvertising.org/ and http://www.networkadvertising.org/mobile-choice. For more information on Google’s privacy practices, see the Google Privacy & Terms page.

In short: If you choose to register or log in to our Services using a social media or third-party account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using third-party account details, like your Google, LinkedIn, or Apple account. Where you choose to do this, we will receive certain profile information about you from that provider. The profile information we receive may vary depending on the provider concerned, but will often include your name, email address, and profile picture, as well as other information you choose to make public on such a platform.

We will use the information we receive only for the purposes described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information.

8. Is Your Information Transferred Internationally?

In short: We may transfer, store, and process your information in countries other than your own.

Our servers are hosted by Hetzner in Germany. If you are accessing our Services from outside Germany, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by the third parties with whom we may share your personal information (see “When and With Whom Do We Share Your Personal Information?” above), including in the United States and other countries.

If you are a resident of the European Economic Area (EEA), United Kingdom (UK), or Switzerland, these other countries may not necessarily have data protection laws as comprehensive as those in your country. We take measures to protect your personal information in accordance with this privacy notice and applicable law, including by using the European Commission’s Standard Contractual Clauses for transfers of personal information between us and our third-party providers. These clauses require recipients to protect all personal information they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses and further details on our safeguards can be provided upon request.

9. How Long Do We Keep Your Information?

In short: We keep your information for as long as necessary to fulfil the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). When you no longer have an account with us, we will delete or anonymise your personal information, except where we are required or permitted by law to retain it.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from further processing until deletion is possible.

10. How Do We Keep Your Information Safe?

In short: We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

11. Do We Collect Information From Minors?

In short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 years of age. If we learn that personal information from users under 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at legal@cognitioncompound.com.

12. What Are Your Privacy Rights?

In short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws, including the right to:

Access — request access to and obtain a copy of your personal information
Rectification — request correction of inaccurate or incomplete personal information
Erasure — request deletion of your personal information
Restriction — request that we restrict the processing of your personal information
Portability — request a copy of your personal information in a portable format, where applicable
Object — object to our processing of your personal information, including for direct marketing
Not be subject to automated decision-making, including profiling, that produces legal or similarly significant effects
Lodge a complaint with your supervisory authority if you believe we are unlawfully processing your personal information

You can exercise these rights by contacting us using the details in “How Can You Contact Us About This Notice?” below. We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you have the right to complain to your Member State data protection authority or the UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time by contacting us using the details in “How Can You Contact Us About This Notice?” below or by updating your preferences. This will not affect the lawfulness of processing before its withdrawal.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking the unsubscribe link in the emails we send, or by contacting us. You will then be removed from the marketing lists, though we may still send service-related messages necessary for the administration and use of your account.

Account Information

If you would like to review or change the information in your account, or terminate your account, you can log in to your account settings and update your user account. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms, and/or comply with applicable legal requirements.

Cookies and similar technologies: Most web browsers are set to accept cookies by default. If you prefer, you can usually set your browser to remove or reject cookies. If you choose to do so, this could affect certain features or services of our Services. See our Cookie Policy: Cookie Policy.

If you have questions or comments about your privacy rights, you may email us at legal@cognitioncompound.com.

13. Controls For Do-Not-Track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there is currently no industry or legal standard for recognising or honouring DNT signals, we do not respond to them at this time.

14. Do United States Residents Have Specific Privacy Rights?

In short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.

Categories of Personal Information We Collect

We have collected the following categories of personal information in the past twelve (12) months:

Category	Examples	Collected
A. Identifiers	Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name	YES
B. Personal information as defined in the California Customer Records statute	Name, contact information, education, employment, employment history, and financial information	YES
C. Protected classification characteristics under state or federal law	Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data	YES
D. Commercial information	Transaction information, purchase history, financial details, and payment information	YES
E. Biometric information	Fingerprints and voiceprints	NO
F. Internet or other similar network activity	Browsing history, search history, online behaviour, interest data, and interactions with our and other websites, applications, systems, and advertisements	YES
G. Geolocation data	Device location	YES
H. Audio, electronic, sensory, or similar information	Images and audio, video, or call recordings created in connection with our business activities	NO
I. Professional or employment-related information	Business contact details, job title, work history, and professional qualifications, including resume and career profile content	YES
J. Education information	Student records and directory information	NO
K. Inferences drawn from collected personal information	Inferences drawn from any of the collected personal information listed above to create a profile or summary about an individual’s preferences and characteristics	NO
L. Sensitive personal information	—	NO

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of receiving help through our customer support channels, participation in customer surveys, and facilitation of our Services.

We will use and retain the collected personal information as needed to provide the Services, and for Categories A, B, C, D, F, G, and I, for as long as the user has an account with us.

Sources of Personal Information. See “What Information Do We Collect?” above.

How We Use and Share Personal Information. See “How Do We Process Your Information?” and “When and With Whom Do We Share Your Personal Information?” above.

We collect and share your personal information through targeting/marketing cookies and beacons/pixels/tags.

Will your information be shared with anyone else? We may disclose your personal information to our service providers pursuant to a written contract between us and each service provider. We may also use your personal information for our own business purposes, such as internal research for technological development and demonstration; this is not considered “selling” of your personal information. Other than the sharing that occurs through the targeting and advertising technologies described above (which may constitute “sharing” under some US state laws, and from which you can opt out), we have not sold personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. The categories of third parties to whom we have disclosed personal information for a business or commercial purpose can be found under “When and With Whom Do We Share Your Personal Information?”

Your Rights

You have rights under certain US state data protection laws, though these rights are not absolute, and in certain cases we may decline your request as permitted by law. These rights include:

Right to know whether or not we are processing your personal data
Right to access your personal data
Right to correct inaccuracies in your personal data
Right to request the deletion of your personal data
Right to obtain a copy of the personal data you previously shared with us
Right to non-discrimination for exercising your rights
Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects

Depending upon the state where you live, you may also have the right to:

obtain a list of the categories of third parties to which we have disclosed personal data
obtain a list of specific third parties to which we have disclosed personal data
limit use and disclosure of sensitive personal data
opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature

How to Exercise Your Rights

To exercise these rights, you can contact us by emailing legal@cognitioncompound.com, or by referring to the contact details at the bottom of this document.

We will honour your opt-out preferences if you enact the Global Privacy Control (GPC) opt-out signal on your browser.

Under certain US state data protection laws, you can designate an authorised agent to make a request on your behalf. We may deny a request from an authorised agent that does not submit proof that they have been validly authorised to act on your behalf.

Request Verification

Upon receiving your request, we will need to verify your identity to determine that you are the same person about whom we have information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. If we cannot verify your identity from the information already maintained by us, we may request additional information for verification and security or fraud-prevention purposes.

If you submit the request through an authorised agent, we may need to collect additional information to verify your identity before processing your request, and the agent will need to provide written and signed permission from you.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing legal@cognitioncompound.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decision. If your appeal is denied, you may submit a complaint to your state attorney general.

California “Shine The Light” Law

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing using the contact details in “How Can You Contact Us About This Notice?“

15. Do Other Regions Have Specific Privacy Rights?

In short: You may have additional rights based on the country you reside in.

Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia’s Privacy Act 1988 and New Zealand’s Privacy Act 2020 (Privacy Act). This privacy notice satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information.

If you do not wish to provide the personal information necessary to fulfil the applicable purpose, it may affect our ability to offer you the products or services you want, respond to or help with your requests, manage your account with us, or confirm your identity and protect your account.

At any time, you have the right to request access to or correction of your personal information by contacting us using the details in “How Can You Review, Update, Or Delete The Data We Collect From You?”

If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and a breach of New Zealand’s Privacy Principles to the Office of New Zealand Privacy Commissioner.

Republic of South Africa

If you are unsatisfied with how we address any complaint regarding our processing of personal information, you can contact the Information Regulator (South Africa):

General enquiries: enquiries@inforegulator.org.za
Complaints (complete POPIA/PAIA form 5): PAIAComplaints@inforegulator.org.za and POPIAComplaints@inforegulator.org.za

16. Do We Make Updates To This Notice?

In short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Last updated” date at the top of this privacy notice. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

17. How Can You Contact Us About This Notice?

If you have questions or comments about this notice, you may contact our Data Protection Officer by email at legal@cognitioncompound.com, or by post at:

Cognition Compound UG (haftungsbeschränkt) Data Protection Officer Sachsenwaldstr. 11A 12157 Berlin Germany

If you are a resident of the European Economic Area or Switzerland, we are the “data controller” of your personal information. You can contact our EEA/Switzerland representative directly regarding our processing of your information by email at legal@cognitioncompound.com, or by post to the address above.

18. How Can You Review, Update, Or Delete The Data We Collect From You?

Based on the applicable laws of your country or state of residence, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please email us at legal@cognitioncompound.com.