Cognipharma takes your privacy extremely seriously. This statement (“Statement”) explains what data and information we collect, how and why we collect it, and how we store, use, disclose, and keep information about you and your interactions with us secure. These interactions include when you use our websites, when you register or attend any Cognipharma event, webinar, trade show, sales, or marketing activities, download an e-book, report or other digital assets, use our online software, forums or online content, you reply to a Cognipharma surveys, and/or if you use any other products or services we provide, including any trial or free versions (collectively the “Services”) in any manner.
We keep this Statement under regular review. Cognipharma may amend this Statement. We will notify you of any changes through our Website and/or through a message to you. This Statement was last updated in Feb 1, 2020.
Who are we?
Cognipharma (collectively “Cognipharma”, “We”, and “Us”) is a digital marketing, software and services company that provides services and technology to companies operating, but not limited to, in the Pharma, Life Sciences and Healthcare industries. You can find our offices locations or contacts at https://www.cognipharma.com.
Cognipharma collects data to operate effectively and provide our Services to you.
- Data provided by You directly: You provide some of this data directly, like when you subscribe to our updates or register in our newsletters or other content updates, register to use software / services we provide, register for a Cognipharma event, or download digital assets like eBooks and reports from our website, register or sign up for a Cognipharma software, trial or demo, or fill out a Contact Request form.
- Job Applicants. When visiting the careers portion of our website or applying through external websites (such as LinkedIn or other job applicant sites), we collect the information that you provide to us in connection with your job application. This includes business and personal contact information, professional credentials and skills, educational and work history, and other information of the type that may be included in a resume. This may also include diversity information that you voluntarily provide. We use this information to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, and monitoring recruitment statistics. We may also use this information to communicate with you, to operate and improve our business, and as otherwise necessary for compliance, fraud prevention, and safety purposes.
- Usage data collected automatically: We also get some information by recording how You interact with Our products and websites by, for example, using technologies like cookies and receiving usage data from the applications / websites used by You.
- Additional data from third parties: We also obtain data from third parties to whom You’ve provided your information and you’ve given Your consent to be transferred to Us. We protect data obtained from third parties according to the practices described in this statement, plus any additional restrictions imposed by the source of the data. These third-party sources may include: data brokers from which we purchase data to supplement the data we collect; service providers that help us determine a location based on your IP address in order to customize certain products to your location; and Cognipharma Partners with which we engage in joint marketing and sales activities.
When you are asked to provide personal data, you may decline. However, if you choose not to provide data that is necessary for us to provide Services, you may not be able to use those Services. The data We collect depends on the consent You’ve provided and on the context of your interactions with Cognipharma, the choices you make, including your privacy settings, and the Services you use. The data we collect can include the following:
- Name and contact data. We collect your first and last name, email address, postal address, phone number, job details, company and position, birthdate, gender, professional identification (e.g. in the case of HCPs, Provider Identifier, State License Number, Medical College/Association numbers, etc. ), and other similar demographic data.
- Credentials. We collect passwords, password hints, and similar security information used for authentication and account access to our Services.
- Usage data. We collect data about your device and how you and your device interactions with Cognipharma, our Services, applications, and Content in Services that we manage. We use unique identifiers to collect and correlate usage data from multiple sources, to provide personalized experiences across different channels and devices, and across multiple sites.
- Location data. For products or Services with location-enhanced features, we collect data about your location, such as a location derived from your IP address or data that indicates where you are located with less precision, such as at a city or postal code level.
- Content. We collect content of your files and communications when necessary to provide you with the Services You use. For example, if You post comments or a file using Our live chat, blog, or collaboration Services. We need to collect the content of that comment or file to display it to You and the other users of the same Services.
We also collect information You provide to Us when You contact Us about the Services and the content of messages You send to Us, such as requested feedback and product or Service reviews You write, or questions and information You provide for customer support. When you contact Us, such as for customer support, phone conversations, or chat sessions with Our representatives may be monitored and recorded.
Cognipharma may also receive information about You from other sources, including third parties from whom We have purchased data, and combine this information with information We already have about You. This helps us to update, expand, and analyze our records, identify new customers, and create more tailored content to provide Services that may be of interest to You.
We do not knowingly collect or solicit Personal Data from anyone under the age of 16. If you are under 16, please do not attempt to register for the Services or send any Personal Data about yourself to us. If we learn that we have collected Personal Data from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us Personal Data, please contact us at [email protected].
- Providing customer support: If You contact our customer service (or vice versa), We will use personal information such as Your order information and contact history to process Your request and provide You with the best service possible. We will process Your personal information in this way if it is necessary for the performance of a contract with Us or if it is required for Us to comply with any legal obligations. If it is not necessary to process Your personal data for either of these reasons, We will process it as it is necessary for the purposes of our legitimate interests in ensuring We can provide the best service possible.
- Engaging with you in relation to the content, programs, software, trainings or other Services you decide to join or consume: We will use Your personal information to provide You with the Services You have requested from Us. This will, if applicable, include the use of Your personal information for submission and publication (on our website or a third-party’s) in relation to Our Services, using Your contact details for events and using information like your location for our apps or websites. We will process your personal information in this way if it is necessary for the performance of a contract with Us. If it is not necessary for the performance of such a contract, we will process it as it is necessary for the purposes of our legitimate interests in providing these Services appropriately and ensuring they function correctly.
- Processing Your orders: We use relevant personal information described above to process and deliver Your order, and to notify You of the status of your order.
- Social sign-on and profiling: this means the use of your social network credentials such as your LinkedIn, Facebook or other Social Networks user login information to create and sign into websites, apps or other online services provided or managed by Cognipharma. We will never post on your behalf, nor engage with your social connections without your explicit confirmation. We use such information to supplement your personal information (e.g. such as to understand which company / companies your have a business relation with). You will always have the opportunity to supplement this profile with any information you would like to share with Us, such as personal information you provide through a completed survey. We will process this personal information as it is necessary for the purposes of our legitimate interests in completing your profile and ensuring we have accurate records about you. To the extent we cannot process it to meet these legitimate interests, we will only process this personal information if you consent to providing it. Any supplemental information you provide to us will be used for the purposes and on the lawful grounds explained in this statement, including to enrich your Cognipharma profile and to personalize your Cognipharma experience.
- Marketing: When you sign up to receive Cognipharma emails, create a Cognipharma single sign on, become a member of websites or apps that we manage, order or provide feedback on a Service, or use our website, we will use your personal information to create a profile based on the information we hold about you. This is necessary for the purposes of our legitimate interests in ensuring we have accurate information about you in one place. We create your profile in accordance with your preferences in order to provide you with the best personalized experience, to send you personalized marketing messages and newsletters and for opinion research purposes, such as:
- What kind of information: The way you interact with our brand across all the different channels described above (e.g. the website, apps, social media and marketing messages we send you) and the information we collect in that regard from each of these channels provides us valuable information about your interests and preferences. This insight gives us the opportunity to offer you the best experience possible. To learn about you and your interests, we analyze your interactions with Us using various kinds of information, as set out above. In particular, we may combine the information we collect with information we lawfully obtain from third parties. This is necessary for the purposes of our legitimate interests in ensuring that we provide you the most appropriate offers for products and to personalize your experience. You can opt-out of us combining your personal information with the information lawfully collected from third parties through your account settings page or by contacting us using the contact details set out below. If you have given us your consent to send you marketing communications or if we are permitted by law to send such communications without obtaining your consent, we use the information that you have provided to us when interacting with us for sending you personalized marketing messages about Cognipharma Services. In some instances, we will also aggregate your personal information with that of other individuals, to create comprehensive reports about how customers use our Services, and experience our brand. This is necessary for the purposes of our legitimate interests in analyzing our brand and determining how to improve our Services.
- What kind of channels: We will send direct marketing communications to you via the channel you choose, such as email, phone, or social media. We ask for your consent, where required by applicable law, in order to use the contact details you have provided to us to send our personalized marketing communications.
- What kind of messages: The messages we will send you will be personalized and tailored to your individual preferences and interests. We use analytics in order to generate such personalized messages. These analytics will process your personal information and place you in marketing segments, which determine the content of the messages and the offers you will receive from us. These direct marketing messages may contain information about our Services, promotions, and news. We personalize these messages because it is necessary for the purposes of our legitimate interests in ensuring that we provide the most appropriate information. We will, in certain circumstances, also use the channels for opinion research (such as to ask if you would like to participate in a survey) and to learn about your experience and improve your experience with Cognipharma, including by sending you personalized messages.
- Re-targeting: Our website and apps use re-targeting technologies, which we will only use after you have provided your consent. This enables us to show our visitors, who were already interested in our Services, advertisements from us on partner websites. We believe that the display of personalized, interest-based advertising is more interesting and relevant to our customers than advertising that does not have a personal connection. Re-targeting technologies analyze the information we collect about your interactions with Us as described in relation to marketing above and information obtained from other parties, including your cookies, and display advertisements based on your past web-surfing behavior. We will process your data for re-targeting purposes with your explicit consent. Please click here for further information on cookies and instructions on how to disable re-targeting. Note that our sites generally are not configured to respond to web browser do-not-track signals.
- Ads: We also work with other companies who use tracking technologies to serve ads on our behalf across the Internet, such as Google, Bing, Facebook, or LinkedIn. These companies may collect personal information about your visits to our websites or apps and your interaction with our communications, including advertising. They will only collect this information to the extent you have consented to the placement of cookies for marketing purposes. Please click here for further information on cookies and instructions on how to change your cookie preferences.
- Conducting analytics: We will use the personal information we hold about you (as well as pseudonymized or anonymized information generated from your personal information) to carry out analysis and research. We carry out all such analysis and research on the basis that it is necessary for the purposes of our legitimate interests in understanding our customers and ensuring that our products meet the needs of our customers.
- Analyzing our business: We will use your personal information (including by anonymizing and aggregating it with other customers’ personal information) for sales, supply chain, and financial analysis purposes, to determine how We are performing, and where improvements can be made and where necessary to report back to our parent or affiliate group companies. This is necessary for the purposes of our legitimate interests in understanding how our business is performing and considering how to improve our performance.
With regard to your information that is collected and/or processed by Cognipharma, you may exercise the following rights:
- Right of access: You may request Cognipharma to confirm if information about you is processed. If such is the case, you will receive access to your information.
- Right of rectification: If our information about you is incorrect, you may request Cognipharma to rectify your information. This includes the right to have incomplete information completed, taking into account the purpose of the processing.
- Right to erasure: You may request Cognipharma to erase your information, for instance if the information is unlawfully processed, or if you have withdrawn your consent.
- Right to restrict processing: You may request Cognipharma to restrict the processing of your information, if (i) the information is inaccurate, (ii) the processing is unlawful, (iii) you need us to retain the information after the retention period for a legal claim, or (iv) you have objected to the processing and a verification of our legitimate interests is pending.
- Right to data portability: You may request Cognipharma to provide you with an electronic file of your information, or to transfer your personal data to a third party if such is technically feasible.
Where you have provided consent, requested a service, or access to a product, Service or Content, we may use your information to:
- process orders that You have submitted, and carry out our obligations arising from any contracts entered into by You and Us;
- perform the Services You’ve requested. For example, if You fill out a “Contact Request” web form, We will use the information provided to contact You about Your interest in the Services;
- seek Your views or comments on the Services we provide, through surveys We may send You;
- notify You of changes to our Services;
- send You communications which You have requested and that may be of interest to You;
- plan and host online or on-site events, host online forums and social networks in which You choose to attend and/or participate, and plan activities, events, promotions related to our Services;
- analyze and create anonymized reports on industry, job, location, interests, or content consumption trends, or more specifically on anonymized data and usage trends on applications or software that You use
- provide you with access to websites, apps, or content with information of events we host or manage;
- process a grant or job application;
- contact You to further discuss Your interest in the Services and to send You information regarding Cognipharma, its partners or customers, such as information about Cognipharma products, partners’ or customers’ products or news, industry content or otherwise relevant information.
We may share Your information with other entities in order to work with them, including Cognipharma partners, contractors or suppliers, third party vendors, service providers and agents. For example, Cognipharma may need to share your information with other companies for customer support, providing some of the Services you contracted with us, marketing, analytics, staff augmentation, hosting or other technical operations, and account management purposes.
We may pass your information to our third-party service providers, for the purposes of completing tasks and providing Services to You on Our behalf (for example to create illustrations, motion graphics, visual designs or other type of content, develop software, host websites, apps or data, provide you with a demo or training of Cognipharma products, to manage content or data on digital properties we manage for you). However, when we use third-party service providers, we disclose only the personal information that is necessary to deliver the Service and we have a contract in place that requires them to keep your information secure, ensure non-disclosure of private information, protection of intellectual property, and not to use it for their own direct marketing purposes unless you have provided Your consent or requested Us to do so, or We are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.
If You do not wish for Your information to be shared in this manner, You may choose not to opt-in via registration forms. If You choose to share Your information with business partners in the manners described above, Your information will be subject to the business partners’ respective privacy statements.
We may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your personal information as set forth in this policy.
Our website or software that we manage will, in certain circumstances, provide you with social plug-ins from various social networks. If you choose to interact with a social network such as Facebook, LinkedIn or Twitter (for example by registering an account), your activity on our website or via our apps will also be made available to that social network. This is necessary for the performance of your contract with Us which allows you to interact with a social network. If you are logged in on one of these social networks during your visit to one of our websites or apps or are interacting with one of the social plug-ins, the social network might add this information to your respective profile on this network based on your privacy settings. If you would like to prevent this type of data transfer, please log out of your social network account before you enter one of our websites or apps, or change the app’s privacy settings, where possible. Please read the privacy policies of those social networks for detailed information about the collection and transfer of personal information, what rights you have and how you can maintain suitable privacy settings for your needs.
Cognipharma will disclose personal information where required by law or legal process, for the administration of justice, to protect your vital interest, for investigations by law enforcement or regulatory bodies, to protect and defend Cognipharma property and legal rights, to protect the personal safety of Cognipharma website, software or content users, or by order of a valid injunction from a court or law enforcement agency.
You have a choice about if You wish to receive information from Us. If You want to receive direct marketing communications from us about the Services and any of our products and services, then you can select your choices by ticking the relevant boxes situated on the form on which we collect your information.
We will not contact you for marketing purposes by email or text message unless you have given your prior consent. You can change your preferences at any time by sending an email to [email protected].
Cognipharma provides blogs or chat rooms on the Cognipharma website, webinar, event or training platforms, or other software (such as apps or collaboration portals) that we manage. Any personal information You choose to submit in such a forum may be read, collected, or used by others who visit those digital properties, and may be used to send you unsolicited messages. Cognipharma is not responsible for the personal information you choose to submit in those forums.
Cognipharma posts a list of customers and testimonials on Cognipharma website that shows information such as customer names and titles. Cognipharma obtains the consent of each customer prior to posting any information on such a list or posting testimonials.
At Cognipharma, We believe You have a right to understand how we protect your applications and data.
We use appropriate technical, organizational and administrative security measures to protect the data supplied by You and managed by Us against loss, misuse, unauthorized access, disclosure, alteration, and destruction. Our security measures are continually improved in line with technological developments. Unfortunately, and despite all our efforts, no company or service can be guaranteed to be 100% secure.
Even considering Cognipharma security endeavours, Our users also play an important role regarding the security of their personal data. The security measures applied on Your assets or the assets of Your company, as well as Your behaviors when using these assets are crucial for maintaining personal data secure. Actions such as defining a weak password to access Our services, not locking Your laptop or mobile device when You left it unattended, or using public assets to login on Our website, all pose a risk. This way, we ask You to take all the necessary precautions in order to avoid security breaches.
List of cookies
A cookie is a small piece of data (text file) that a website – when visited by a user – asks your browser to store on your device in order to remember information about you, such as your language preference or login information. Those cookies are set by us and called first-party cookies. We also use third-party cookies – which are cookies from a domain different than the domain of the website you are visiting – for our advertising and marketing efforts.
Links to other websites
Our website may contain links to other websites run by other organizations. This Statement applies only to our website‚ so We encourage You to read the privacy statements on the other websites You visit. We cannot be responsible for the privacy policies and practices of other sites even if You access them using links from our website.
In addition, if You linked to Our website from a third-party site, We cannot be responsible for the privacy policies and practices of the owners and operators of that third-party site and recommend that You check the Statement of that third-party site.
We work with customers in multiple countries, and have databases in different countries, some of which are operated by third parties on behalf of Cognipharma (such as cloud or hosting providers). We may transfer Your data to one of the Cognipharma databases outside Your country of domicile, potentially including countries which may not require an adequate level of protection for your personal data compared with that provided in your country. For instance, if You use our Services while you are outside the European Union (EU) region, your information may be transferred outside the EU in order to provide you with those Services. We ensure there are adequate safeguards in place when transferring Your data outside Your country and the EU, including by relying on Privacy Shield, Model Clauses, or other lawful mechanisms or otherwise that the transfer only occurs where permitted by applicable law, with the aim of ensuring that your privacy rights continue to be protected as outlined in this Statement
We use third-party and Cognipharma own technology to improve our website and product experience and usability. It collects information such as mouse clicks, mouse movements, page scrolling, and any text keyed into website forms, for aggregated and statistical reporting. This service is only on the Cognipharma website, Our software or websites and software that we manage, and is for internal use only. We anonymize your personal data to the extent possible; however, for technical reasons, we cannot assure full anonymization. We process your personal data under our legitimate interest in improving our service, under art. 6, par. 1, lit f), GDPR. You can contact us and object to such processing.
We will keep your personal information for two years from your last interaction with us, such as the date your account was deleted, your last order, the last time you used one of our apps, or in some other way contacted or interacted, unless a longer or shorter retention period is required by law, is necessary in the course of legal proceedings, or is otherwise needed for a particular purpose under applicable law.
The following are examples of how Cognipharma might keep your personal information for as long as necessary for a particular purpose:
- We may keep your personal information collected during a purchase of a Service for as long as required by tax laws (up to ten years in Portugal);
- We may keep your personal information for a shorter period if you ask us to delete your personal information. In such a case, Cognipharma will aim to delete your personal information within a maximum period of one month from the date of the request.
In general, We will hold Your personal information on Our systems for as long as is necessary for the relevant Service, or as long as is set out in any relevant contract You hold with Us and for a reasonable period of time afterward, for instance to pursue Our legitimate business interests, conduct audits, comply with Our legal obligations, resolve disputes, and enforce our agreements.
We review our retention periods for personal information on a regular basis.
If you have registered for an account with Cognipharma or provided your consent through any channel we manage, you may generally update your user settings, profile and, organization’s settings by logging into the Cognipharma website or into the applicable Service with your username and password and editing your settings or profile. To update your information, discontinue your account, and/or request return or deletion of Your data associated with your account, please contact [email protected] For other requests to access, correct, modify or delete Your personal information, please contact [email protected]
We will respond to your requests without undue delay, but within one month. If permitted under applicable legislation, Cognipharma may extend the response period with two further months if such is necessary due to the complexity and number of requests. Cognipharma will notify you of any extension and the reason thereof. If Cognipharma denies Your request, We shall inform You on the reasons for such a denial.
If information about You is processed by Cognipharma on behalf of one of our customers, partners or service providers, We will forward Your request to the relevant party. We will inform You that We have forwarded your request and provide You with the contact details of the relevant party.
All of our marketing communications contain an easy way to opt out from receiving future messages, such as a link through which you can unsubscribe. If you would like to opt out of receiving Cognipharma marketing messages you may use the unsubscribe link contained in the messages you have received, or alternatively you can contact [email protected]
Note that if you choose to opt out of receiving marketing messages in the manner explained above, we will continue to process your personal information, in particular to allow us to understand your interests and preferences, but we will stop using your personal information to send you personalized or non-personalized marketing messages. If you would like us to stop such processing in part or in full, we have explained how to do this in the above paragraph.
If you have any questions, comments or requests regarding this Statement or Our processing of your information, please contact:
Cognipharma Management Director
LACS Cascais, Estr. Malveira da Serra 920
2750-834 Cascais | Portugal
Tel: +351 934 989 433