# PRIVACY POLICY

**COGNATIC LABS, INC.**
A Delaware Corporation

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**Last Updated:** June 2, 2025
**Effective Date:** June 2, 2025

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## COMPANY INFORMATION

**Cognatic Labs, Inc.**
A Delaware Corporation
Delaware File Number: 7842156
Date of Incorporation: March 15, 2024

**Corporate Headquarters:**
Bayside Technology Center
46527-46669 Fremont Blvd, Suite 240
Fremont, CA 94538
Phone: (510) 555-0147
Email: info@cognaticlabs.com
Website: www.cognaticlabs.com

**Delaware Registered Agent:**
Corporation Service Company
251 Little Falls Drive
Wilmington, DE 19808

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## 1. INTRODUCTION

This Privacy Policy describes how Cognatic Labs, Inc. (“Company,” “we,” “us,” or “our”) collects, uses, discloses, and protects your personal information when you use our artificial intelligence services, visit our website at www.cognaticlabs.com, or otherwise interact with our services (“Services”).

We are committed to protecting your privacy and maintaining the confidentiality of your personal information in accordance with applicable federal and state privacy laws, including the California Consumer Privacy Act (CCPA), California Privacy Rights Act (CPRA), and other relevant privacy regulations.

**BY USING OUR SERVICES, YOU CONSENT TO THE COLLECTION, USE, AND DISCLOSURE OF YOUR PERSONAL INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY.**

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## 2. INFORMATION WE COLLECT

### 2.1 Personal Information You Provide

We collect personal information that you voluntarily provide to us, including:

– **Identity Information:** Name, username, email address, phone number, company name, job title
– **Account Information:** Login credentials, account preferences, profile information
– **Communication Data:** Messages, feedback, support requests, survey responses
– **Business Information:** Company details, project requirements, technical specifications
– **Payment Information:** Billing address, payment method details (processed through third-party payment processors)

### 2.2 Information Collected Automatically

When you use our Services, we automatically collect:

– **Usage Data:** Pages visited, features used, time spent, click patterns, navigation paths
– **Device Information:** IP address, browser type and version, operating system, device identifiers
– **Technical Data:** Log files, error reports, performance metrics, API usage statistics
– **Location Data:** General geographic location based on IP address (city/state level)

### 2.3 AI-Related Data Collection

As an artificial intelligence company, we may collect additional information related to our AI services:

– **Input Data:** Text, images, files, or other content you submit to our AI systems
– **AI Interaction Data:** Prompts, queries, commands, and responses generated through AI interactions
– **Training Data:** Aggregated and anonymized data used to improve our AI models (only with explicit consent)
– **Performance Metrics:** Data about AI model accuracy, response times, and effectiveness

### 2.4 Cookies and Tracking Technologies

We use cookies, web beacons, and similar tracking technologies to collect information about your use of our Services:

– **Essential Cookies:** Required for basic website functionality and security
– **Analytics Cookies:** Used with Google Analytics to understand website usage patterns
– **Functional Cookies:** Remember your preferences and settings
– **Marketing Cookies:** Track interactions for advertising and promotional purposes (with consent)

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## 3. HOW WE USE YOUR INFORMATION

### 3.1 Primary Purposes

We use your personal information for the following purposes:

– **Service Provision:** Deliver, maintain, and improve our AI services
– **Account Management:** Create and manage user accounts, authenticate users
– **Customer Support:** Respond to inquiries, provide technical assistance, troubleshoot issues
– **Communication:** Send service updates, security alerts, administrative messages
– **Personalization:** Customize user experience and provide relevant content
– **Research and Development:** Improve existing services and develop new AI capabilities

### 3.2 AI-Specific Uses

– **Model Training:** Improve AI algorithms using aggregated, anonymized data (with consent)
– **Quality Assurance:** Monitor AI output quality and accuracy
– **Safety and Security:** Detect and prevent misuse of AI systems
– **Performance Optimization:** Enhance AI response times and effectiveness

### 3.3 Legal Bases for Processing (GDPR Compliance)

For users in the European Economic Area, our legal bases for processing include:

– **Consent:** When you explicitly agree to processing for specific purposes
– **Contract Performance:** To fulfill our service agreements with you
– **Legitimate Interest:** For business operations, security, and service improvement
– **Legal Obligation:** To comply with applicable laws and regulations

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## 4. INFORMATION SHARING AND DISCLOSURE

### 4.1 Third-Party Service Providers

We may share your information with trusted third-party service providers who assist us in operating our business:

– **Cloud Infrastructure:** AWS, Google Cloud Platform, Microsoft Azure
– **Analytics Services:** Google Analytics, Mixpanel, Amplitude
– **Payment Processing:** Stripe, PayPal (we do not store payment card information)
– **Customer Support:** Zendesk, Intercom
– **Email Services:** SendGrid, Mailchimp
– **Security Services:** Cloudflare, Auth0

### 4.2 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred as part of the business transaction. We will provide notice before your information is transferred and becomes subject to a different privacy policy.

### 4.3 Legal Requirements

We may disclose your information when required by law or to:

– Comply with legal processes, court orders, or government requests
– Protect our rights, property, or safety, or that of others
– Investigate fraud, security breaches, or illegal activities
– Enforce our Terms of Service or other agreements

### 4.4 With Your Consent

We may share your information for other purposes with your explicit consent.

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## 5. ARTIFICIAL INTELLIGENCE DISCLOSURES

### 5.1 AI Technology Use

**IMPORTANT: Our services utilize artificial intelligence technologies, including machine learning algorithms and automated decision-making systems.** When you interact with our Services, you may be communicating with AI systems rather than human operators.

### 5.2 AI-Generated Content

– AI-generated content may not always be accurate or complete
– AI outputs should be reviewed and verified before making important decisions
– We do not guarantee the accuracy, reliability, or appropriateness of AI-generated content
– Users are responsible for validating AI outputs for their specific use cases

### 5.3 Automated Decision-Making

We may use automated decision-making processes, including AI algorithms, for:

– Content personalization and recommendations
– Fraud detection and security monitoring
– Service optimization and performance enhancement
– Customer support routing and prioritization

**You have the right to request human review of automated decisions that significantly affect you.**

### 5.4 AI Model Training

We may use aggregated, anonymized data to train and improve our AI models. This helps us:

– Enhance AI accuracy and performance
– Develop new features and capabilities
– Reduce bias and improve fairness in AI outputs
– Ensure AI safety and security

**You can opt out of AI model training by contacting us at ai-privacy@cognaticlabs.com.**

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## 6. GOOGLE ANALYTICS AND COOKIES

### 6.1 Google Analytics

We use Google Analytics to analyze website usage and improve our Services. Google Analytics collects information such as:

– How often users visit our website
– What pages they visit when they do so
– What other sites they used prior to coming to our website

We use this information to improve our website and Services. Google Analytics collects only the IP address assigned to you on the date you visit our website, rather than your name or other personally identifying information.

**Google Analytics Data Processing:** Google may use the data collected to contextualize and personalize the ads of its own advertising network. To opt out of Google Analytics, you can install the Google Analytics opt-out browser add-on available at: https://tools.google.com/dlpage/gaoptout

### 6.2 Cookie Consent

**By continuing to use our website, you consent to our use of cookies as described in this Privacy Policy.** You can control cookie settings through your browser preferences:

– **Accept All Cookies:** Allow all cookies for full website functionality
– **Reject Non-Essential:** Block marketing and analytics cookies while maintaining essential functionality
– **Custom Settings:** Choose specific cookie categories to allow

### 6.3 Third-Party Cookies

Our website may contain cookies from third-party services:

– **Google Analytics:** _ga, _gid, _gat cookies for website analytics
– **Google Tag Manager:** For managing tracking codes
– **Social Media:** Cookies from embedded social media content

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## 7. DATA RETENTION

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

**Retention Periods:**

– **Account Information:** Retained while your account is active and for 7 years after closure
– **Usage Data:** Retained for 26 months (Google Analytics standard)
– **Support Communications:** Retained for 3 years
– **AI Interaction Data:** Retained for 12 months unless deletion is requested
– **Marketing Data:** Retained until you unsubscribe or for 3 years of inactivity

**Automated Deletion:** We implement automated systems to delete data when retention periods expire.

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## 8. DATA SECURITY

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction:

### 8.1 Technical Safeguards

– **Encryption:** Data encrypted in transit (TLS 1.3) and at rest (AES-256)
– **Access Controls:** Role-based access with multi-factor authentication
– **Network Security:** Firewalls, intrusion detection, and monitoring systems
– **Secure Infrastructure:** SOC 2 compliant cloud providers and data centers

### 8.2 Organizational Safeguards

– **Privacy Training:** Regular privacy and security training for employees
– **Data Minimization:** Collect and process only necessary information
– **Regular Audits:** Periodic security assessments and vulnerability testing
– **Incident Response:** Established procedures for data breach response

### 8.3 Data Breach Notification

In the event of a data breach that poses a risk to your personal information, we will:

– Notify affected individuals within 72 hours of discovery
– Report the breach to relevant regulatory authorities as required
– Provide details about the breach and steps being taken to address it
– Offer assistance and resources to affected individuals

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## 9. YOUR PRIVACY RIGHTS

### 9.1 California Residents (CCPA/CPRA Rights)

If you are a California resident, you have the following rights:

**Right to Know:**
– Request disclosure of personal information collected, used, or shared
– Obtain specific pieces of personal information we have about you
– Learn about our data practices and third-party sharing

**Right to Delete:**
– Request deletion of personal information we have collected
– Exceptions apply for certain legal, safety, and operational purposes

**Right to Correct:**
– Request correction of inaccurate personal information

**Right to Opt-Out:**
– Opt out of the sale or sharing of personal information
– Opt out of targeted advertising
– Opt out of automated decision-making and profiling

**Right to Non-Discrimination:**
– You cannot be discriminated against for exercising your privacy rights

**Right to Limit Sensitive Information:**
– Limit the use and disclosure of sensitive personal information

### 9.2 All Users Rights

Regardless of your location, you may:

– **Access:** Request information about our data practices
– **Update:** Correct or update your account information
– **Delete:** Request deletion of your account and associated data
– **Portability:** Receive a copy of your data in a portable format
– **Opt-Out:** Unsubscribe from marketing communications

### 9.3 Exercising Your Rights

To exercise your privacy rights:

**Email:** privacy@cognaticlabs.com
**Phone:** (510) 555-0147
**Mail:**
Privacy Officer
Cognatic Labs, Inc.
46527-46669 Fremont Blvd, Suite 240
Fremont, CA 94538

**Verification Process:** We may require verification of your identity before processing requests to protect your personal information.

**Response Time:** We will respond to verified requests within 45 days (extendable by 45 days for complex requests).

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## 10. CHILDREN’S PRIVACY (COPPA COMPLIANCE)

Our Services are not directed to children under the age of 13. We do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under 13, we will delete that information promptly.

**For users aged 13-17:** We require parental consent before collecting personal information for marketing purposes or targeted advertising.

If you believe we have collected information from a child under 13, please contact us immediately at privacy@cognaticlabs.com.

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## 11. INTERNATIONAL DATA TRANSFERS

### 11.1 Cross-Border Transfers

We may transfer your personal information to countries outside your country of residence, including the United States. These countries may have different data protection laws than your country.

### 11.2 Safeguards for EU Data

For personal information transferred from the European Economic Area:

– **Adequacy Decisions:** We rely on European Commission adequacy decisions where available
– **Standard Contractual Clauses:** We use EU-approved Standard Contractual Clauses
– **Certification Programs:** We participate in relevant certification programs
– **Additional Safeguards:** We implement supplementary measures to ensure adequate protection

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## 12. CALIFORNIA “SHINE THE LIGHT” LAW

California residents who provide personal information to obtain products or services for personal, family, or household use may request information about our disclosure of personal information to third parties for their direct marketing purposes.

To make such a request, please contact us at:
**Email:** privacy@cognaticlabs.com
**Subject Line:** “California Shine the Light Request”

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## 13. DO NOT TRACK SIGNALS

Our website does not currently respond to “Do Not Track” signals from browsers. However, you can control tracking through:

– Browser cookie settings
– Google Analytics opt-out tools
– Third-party privacy tools and extensions

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## 14. UPDATES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.

**Notification of Changes:**
– We will post the updated Privacy Policy on our website
– We will update the “Last Updated” date at the top of this policy
– For material changes, we will provide additional notice via email or website banner
– Continued use of our Services after changes constitutes acceptance of the updated policy

**Review Recommendation:** We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

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## 15. CONTACT INFORMATION

### 15.1 Privacy Inquiries

For questions about this Privacy Policy or our privacy practices:

**Privacy Officer**
Cognatic Labs, Inc.
46527-46669 Fremont Blvd, Suite 240
Fremont, CA 94538

**Email:** privacy@cognaticlabs.com
**Phone:** (510) 555-0147
**Business Hours:** Monday-Friday, 9:00 AM – 5:00 PM PST

### 15.2 AI-Specific Privacy Questions

For questions specifically related to AI data processing:

**Email:** ai-privacy@cognaticlabs.com
**Subject Line:** Include “AI Privacy Inquiry” for faster processing

### 15.3 Data Protection Officer

For GDPR-related inquiries:

**Email:** dpo@cognaticlabs.com
**Phone:** (510) 555-0147

### 15.4 Legal and Compliance

For legal and compliance matters:

**Email:** legal@cognaticlabs.com
**Mail:**
Legal Department
Cognatic Labs, Inc.
46527-46669 Fremont Blvd, Suite 240
Fremont, CA 94538

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## 16. GOVERNING LAW

This Privacy Policy is governed by the laws of the State of Delaware, without regard to its conflict of laws principles. Any disputes arising from this Privacy Policy will be subject to the exclusive jurisdiction of the courts of Delaware.

**Federal Law Compliance:** This Privacy Policy also complies with applicable federal laws, including but not limited to COPPA, CAN-SPAM Act, and FTC regulations.

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## 17. ACCESSIBILITY

We are committed to ensuring this Privacy Policy is accessible to all users. If you need this information in an alternative format, please contact us at accessibility@cognaticlabs.com.

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## 18. SEVERABILITY

If any provision of this Privacy Policy is found to be unenforceable or invalid, that provision will be limited or eliminated to the minimum extent necessary so that this Privacy Policy will otherwise remain in full force and effect.

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**Cognatic Labs, Inc.**
Delaware File Number: 7842156
Federal EIN: 88-1234567
California Foreign Corporation No: 202412345678

**© 2025 Cognatic Labs, Inc. All rights reserved.**

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*This Privacy Policy was last updated on June 2, 2025, and is effective immediately for all users of our Services.*