Privacy Policy of Cogram
Cogram takes the confidentiality and the protection of user data very seriously. Cogram processes personal data only to the extent permissible under statutory provisions, in particular under the EU General Data Protection Regulation (“GDPR”).
With this Privacy Policy Cogram would like to inform you about the nature of the processing of personal data via Cogram’s website “cogram.com” (hereinafter “Website”) and in providing Cogram’s services (“Services”), the purposes of such data processing, and about the rights to which you are entitled, in accordance with Art. 13 GDPR.
The Privacy Policy of Cogram uses terms used by the European legislature GDPR. Cogram’s Privacy Policy should be legible and understandable for the general public as well as for Cogram’s customers and business partners. To ensure this, we would like to explain the terms used in advance.
In this Privacy Policy, we use, among other things, the following terms:
Personal data is any information relating to an identified or identifiable natural person. A natural person is considered to be identifiable if, directly or indirectly, in particular by means of assignment to an identifier such as a name, an identification number, location data, an online identifier or to one or more special features, the expression of the physical, physiological, genetic, psychological, economic, cultural or social identity of this natural person can be identified.
Data subject is any identified or identifiable natural person whose personal data is processed by the data controller.
Processing is any process carried out with or without the help of automated processes or any such series of processes in connection with personal data such as collecting, recording, organizing, arranging, storing, adapting or changing, reading out, querying, the use, disclosure by transmission, distribution or any other form of making available, matching or linking, restriction, deletion or destruction.
Blocking of processing is the marking of stored personal data with the aim of restricting their future processing.
Profiling is any type of automated processing of personal data that consists of using such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects relating to that natural person's job performance, economic situation, health, personal preferences, interests, reliability, behavior, location or change of location.
The person responsible or responsible for processing is the natural or legal person, authority, institution or other body that alone or jointly with others decides on the purposes and means of processing personal data. If the purposes and means of this processing are specified by Union law or the law of the Member States, the person responsible or the specific criteria for his naming can be provided for by Union law or the law of the Member States.
The Processor is a natural or legal person, public authority, institution or other body that processes personal data on behalf of the person responsible.
Consent is any expression of will voluntarily given by the data subject in an informed manner and unequivocally for the specific case in the form of a declaration or other clear confirmatory action with which the data subject indicates that they consent to the processing of their personal data is.
We, Cogram Inc., 2918 Avenue I #1036 Brooklyn, NY 11210 USA (hereinafter “we”), are responsible for processing your personal data pursuant to applicable data privacy law, including Art. 4 (7) GDPR.
You can contact us at info@cogram.com, in case you have any questions regarding the processing of your personal data.
Cogram may use external third party providers such as cloud infrastructure providers to provide Cogram’s Website or Services. If Cogram uses external service providers, these have been carefully selected by us and commissioned in writing and only process your personal data on Cogram’s behalf. If necessary, we have concluded a processing agreement pursuant to Art. 28 GDPR with third party providers.
We may transfer your personal data to non-EU/EEA countries. Insofar there is no adequacy decision for such countries according to Art. 45 GDPR, we transfer your personal data subject to appropriate safeguards according to Art. 46 GDPR.
Your personal data will be deleted or blocked as soon as the purpose for processing no longer applies. We will further retain your data if we are legally obliged to do so, especially for tax and accounting purposes. Blocking or deletion of your personal data will also take place if a retention period prescribed by the standards expires, unless there is a need for further storage of the data for the conclusion or performance of a contract.
As a responsible company, we do not use automatic decision-making or profiling.
We do not intend for children under 13 years of age to interact with us on Cogram Website or otherwise to store or process personal data of children under the age of 13. No one under age 13 may provide any personal data to Cogram’s Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on Cogram’s Website or through any of its features, register on Cogram’s Website, use any of the interactive or public comment features of Cogram’s Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal data from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at info@cogram.com. California residents under 16 years of age may have additional rights regarding the collection and sale of their personal data.
In the following we would like to provide an overview of the personal data we collect and process, the purposes we process them for as well as the legal basis for such processing activity.
Each time you access Cogram’s Website, the following personal data is automatically collected and processed:
The legal basis for this processing includes Cogram’s legitimate interest (Art. 6 (1) (f) GDPR). We weighed Cogram’s interest in providing as well as operating and securing Cogram’s Website against your interest in the confidentiality of Cogram’s personal data, whereby Cogram’s interest prevails. Without the processing of personal data, the provision of Cogram’s Website is technically impossible. This also applies to its operation and security. In this context, the security of Cogram’s Website also serves your interests.
When you sign up for Cogram’s services, you provide and we process your email address and any information you provide in Cogram’s sign-up form. We require this information to provide Cogram’s Services to you and authenticate you. Further we process your name and banking information you provide us with. The legal bases for the processing of your personal data include the initiation of and performance of a contractual relationship in accordance with Article 6 (1) (b) GDPR.
We transfer your personal data to third party service providers, such as cloud services and payment providers.
When you use Cogram’s Service we transcribe meetings on your behalf and receive information about those meetings, such as the date and time of the meeting and the attendees’ names, identifiers used in meetings, and email addresses.
Meeting audio is transcribed but no meeting audio or video recordings are stored after transcription. Meeting transcripts are stored and used to generate meeting summaries, notes, and action items. All meeting data is encrypted in transit, and stored in encrypted databases on AWS cloud infrastructure.
When you have a direct contractual relationship with us the legal basis for processing of your personal data is the performance of a contractual relationship in accordance with Article 6 (1) (b) GDPR.
When Cogram’s Services are used by your employer or other third parties, we process your personal data as a processor according to Art. 4 No. 8 GDPR. Your employer or the third party using Cogram’s Service is responsible for the collection of your personal data and for ensuring that there is a valid legal basis for doing so.
We use functional cookies and other automatic data collection technologies (such as web beacons and pixel tags, which are small electronic files) in order to gather statistics related to Cogram’s Website and to ensure functionality of Cogram’s Website. Cookies are small text files that store information on the user behavior when visiting a website and that are placed on the user’s computer and held available for further visits to the website. We take reasonable precautions to ensure that these cookies do not cause any damage to your computer and do not contain any viruses.
The information obtained using functional cookies will not be linked to your IP address. No other personal data is collected through the use of functional cookies. We use the information contained in these cookies to enable, analyze and improve the operation and use of Cogram’s Website and in order to ensure Cogram’s IT security.
You may also visit Cogram’s Website without cookies being used, provided that you have disabled the storage of cookies by adjusting your browser settings accordingly. However, in doing so, you may not be able to use all functions of Cogram’s Website.
The legal bases for the data processing include Cogram’s legitimate interest (Art. 6 (1) (f) GDPR). We weighed our interest in providing the cookie-dependent functions of Cogram’s Website against your interest in the confidentiality of your personal data, whereby Cogram’s interest prevails. Without the processing of personal data, it is not technically possible to provide the functions. At the same time, the option outlined above is open to you to prevent the processing of your personal data in connection with cookies.
As soon as you close your browser, the session cookie is automatically deleted by default, unless you have made a different setting in the cookie settings of your browser.
Google Analytics
We use Google Analytics on Cogram’s Website, a web analytics service provided by Google Ireland Limited, Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google").
Google Analytics uses so-called tracking pixels and cookies. The information generated by a cookie about your use of Cogram’s Website is usually transmitted to a Google server in the USA and stored there. However, by activating IP anonymization, your IP address will be shortened by Google beforehand within the European Economic Area (European Union and other member states). Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there.
On Cogram’s behalf, Google will use this information for the purpose of evaluating your use of Cogram’s Website, compiling reports on Website activity and providing us with other services relating to Website activity and internet usage. The IP address transmitted by your browser as part of Google Analytics will not be merged with other data from Google.
The processing of your personal data is based on your consent (Art. 6 (1) lit. a GDPR). You can revoke your consent by changing your cookie preferences.
Google processes your personal data in the USA. There is no adequacy decision of the European Commission for the USA. We have secured the level of data protection with appropriate guarantees (so-called standard contractual clauses) within the meaning of Art. 46 DSGVO.
In accordance with the GDPR, you may have the following rights regarding your personal data:
If we process your personal data based on Cogram’s legitimate interests (Art. 6 (1) (f) GDPR), you can object to the processing by contacting us (see “Controller” for contact details). The same applies if we process your data based on your consent, you have the right to revoke your consent at any time with effect for the future.
Furthermore, you are entitled to lodge a complaint with a supervisory authority regarding the processing of your personal data.
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