#1. Who We Are
Coggno Inc. (“Coggno,” “we,” “us”) runs coggno.com, app.coggno.com, our apps and related services (together, the “Service”).
- Address: Coggno Inc., 1165 Lincoln Ave Suite #150-8658, San Jose, CA 95125, United States
- Privacy contact: [email protected]
#2. Who This Policy Covers
This policy covers website visitors, people who hold a Coggno account (administrators, Marketplace buyers and course authors) and learners who take training on Coggno.
Our Role Depends on How You Use Coggno
When you visit coggno.com, buy courses or hold your own account, Coggno decides how your information is used. In privacy law terms, we are the “controller.”
When an employer or other organization (a “Customer”) uses Coggno to train its people, the Customer decides how learner information is used, and we handle it on the Customer’s behalf under our agreement with them. We are the Customer’s “processor” or “service provider.” If your training was assigned by a Customer, the Customer’s own privacy notice also applies, and we will pass your requests about those records to the Customer.
#3. Information We Collect
| Type | Where it comes from |
|---|---|
| Account and profile details | You, your organization’s administrator, or your organization’s HR system when it connects one |
| Training records | Created as you use the Service, and by your administrator |
| Purchase and billing details | You. Card details go to our payment processor. |
| Content you upload | You |
| Device, usage and advertising information | Collected automatically by cookies and similar tools (Section 6), and from the link you clicked when you arrive from an ad |
| Messages to us | You |
You don’t have to give us personal information, but without some of it, such as your name and email, we can’t set up an account.
#4. How We Use Information
The last column gives the legal basis we rely on for people in the European Economic Area, the UK and Switzerland.
| Purpose | Legal basis |
|---|---|
| Provide the Service: create accounts, deliver courses, track progress, issue certificates, let administrators assign training and run reports, and send service email | Performance of a contract |
| Process payments, subscriptions and invoices, and calculate sales tax | Performance of a contract; legal obligation |
| Let anyone with a certificate’s link confirm it is genuine | Legitimate interests: letting employers and auditors check certificates |
| Keep the Service secure and prevent fraud and abuse | Legitimate interests |
| Understand how the Service is used and improve it | Legitimate interests; consent where cookies need it |
| Send marketing email about courses and features | Consent, or legitimate interests where the law allows. You can unsubscribe anytime. |
| Measure which ads lead to purchases and sign-ups | Consent |
| Comply with law and enforce our terms | Legal obligation; legitimate interests |
We don’t use learners’ training records for advertising.
#5. How We Share Information
- Your organization. If a Customer gave you access, it can see your profile and training records, including through integrations it turns on.
- Service providers that run parts of the Service for us under contract, such as hosting, payments, email, analytics, scheduling and HR-system connections. Our subprocessors are listed on our Subprocessors page.
- Certificate verification and sharing. Each certificate has a verification page that anyone with its link can open. If you choose to share a certificate on another site, that site’s privacy policy applies.
- Advertising platforms. When someone buys or signs up on Coggno after clicking an ad, we send that platform identifiers (such as the click ID, hashed contact details and IP address), browser details and purchase or sign-up details, so it can report which ads worked.
- Course authors. If you buy a course on the Marketplace, its author can see your name and order details (the course, date, quantity and total), and who holds licenses to their courses.
- Legal and safety. When the law or legal process requires it, or to protect the rights, safety and property of Coggno, our users or others.
- Business transfers. If Coggno is part of a merger, acquisition or sale of assets, information may move to the new owner under this policy.
#6. Cookies and Similar Technologies
We use cookies and similar technologies to sign you in, keep the Service secure and working, remember your choices, understand how the Service is used, and measure our marketing. Our advertising and analytics partners may collect information about your activity on our sites over time and across other websites.
On coggno.com, use Cookie Settings in the footer to change your choices at any time. Our sites don’t respond to browser “Do Not Track” signals, which have no common standard. You can also block or delete cookies in your browser settings, though the Service won’t work without essential cookies.
#7. Where We Store and Transfer Information
Coggno is based in the United States and stores information in the United States. Some service providers process information in other countries.
When we transfer personal information from the European Economic Area, the UK or Switzerland, we use the European Commission’s Standard Contractual Clauses and the matching UK and Swiss mechanisms. You can ask us for a copy at [email protected].
#8. How Long We Keep Information
- Account details: while the account is active, or until deletion is requested.
- Customer data, such as training records and certificates: as our agreement with the Customer provides.
- Tax records: as long as tax law requires.
- Marketing contacts: until you unsubscribe.
- Logs and backups: for a limited period.
#9. How We Protect Information
We use reasonable technical and organizational measures to protect personal information.
#10. Your Rights and Choices
Everyone
- Your account: many fields can be edited in Settings.
- Marketing email: use the unsubscribe link in any marketing email.
- Cookies: use Cookie Settings in the footer of coggno.com.
European Economic Area, UK and Switzerland
You have the right to access, correct, delete and export your personal information, to restrict how we use it, and to withdraw consent at any time.
You also have the right to object to our use of your personal information based on our legitimate interests, including for direct marketing.
You can complain to us at [email protected] and to your local data protection authority.
How to Make a Request
Email [email protected] from the address on your account. We may need to confirm your identity before acting. We reply within the time the law requires. If we can’t fulfill a request, we’ll tell you why.
#11. Children
Coggno is built for workplace training. It isn’t directed to children under 13, and we don’t knowingly collect personal information from them. If you believe a child has given us information, contact us and we will delete it.
#12. Changes to This Policy
We update this policy when our practices change. The date at the top shows when it last changed. For material changes, we’ll tell you by email or in the Service before they take effect.
#13. Contact Us
Questions about this policy or your information: [email protected].