Last Modified: November 14, 2023
Cognia, Inc. ®, formerly Advance Education, Inc. (AdvancED) and dba Cognia, Inc. (“Cognia”, “we”, “us” or “our”) appreciates the value of your trust, and we understand the importance of protecting your privacy. This privacy notice (the “Privacy Notice”) sets forth our privacy practices and policies and describes the type of information we collect about you, how and when we collect it, how we use it, with whom we may share your information, and your rights regarding our use of your information. This Notice applies to all information collected through your interaction or communication with us, whether electronic, written or oral; information collected on Cognia websites (“Sites”) that include a link to this Privacy Notice or a link to terms which incorporate this Privacy Notice, and through Cognia mobile applications (“Apps”); our online community, portals and networks which may connect users of Cognia’s services to each other (“Learning Community”); and information collected offline, collected or received from third parties or through your interactions with us related to your use of our products and services, (collectively, Sites, Apps, Learning Community and offline or third-party information are referred to herein as the “Services”). By accessing our Services or providing your information to us, you accept and agree to the practices described in this Privacy Notice.
From time to time, we may clarify, revise or update this Notice. This may include making changes to the way we collect, maintain and store information. If we make changes to this Notice, we will update the “last modified” date at the top of this Notice. Changes to this Notice will be effective once they are posted, and your use of the Services after such changes are made represent your acceptance of the revised Privacy Notice.
This Policy does not apply to information collected or received through other means, to information collected by any third party, including websites or applications we may link to, or the collection, use and sharing of deidentified or anonymous data. Third-party websites and applications may be subject to their own privacy notices.
We collect information from several sources. The information we collect depends on how you interact with our Services. Cognia collects information that identifies or can be used to identify or authenticate you as an individual, collectively referred to in this Privacy Notice as “Personal Information”.
Personal Information may include, but is not limited to:
We collect information that you provide to us when you interact with our Site or Services, through surveys, or through other communications. We may collect data from entities you have requested or authorized to provide information to us in connection with a Service.
For example, we collect information when you:
We may collect the following information, including as reasonably required to complete a request, provide a Service, or complete a transaction on your behalf: first and last name, home or other physical address, telephone number, email address, other identifiers that permit an individual to be contacted physically or online, date of birth, data about transactions with us (such as Service purchase history), Institution name and address (if applicable), shipping options and instructions, employment and professional information, credit or debit card number and other financial information, race, disability status, voice recordings, or other information.
We may collect information automatically using data collection technologies such as cookies, web beacons, pixel tags or other similar current and future technologies as they develop (the “Data Technologies”). We may have access to information automatically collected by Data Technologies across our Site, third-party websites and mobile applications, or as compiled by marketing and advertising partners.
When you download or use our mobile application or use mobile devices to access our Sites, we may receive information about your location and your mobile device by, for example, using satellite, cell phone tower or Wi-Fi- signals. This may include a unique identifier for your device, device settings, analytical information about how you use your mobile device and other information that may be stored on or accessed through your mobile device. In some cases, we may receive information from mobile applications not operated by us or from other devices connected to your mobile device.
Information collected automatically, including through Data Technologies, may include: your IP address and associated activity tracking; the type of computer or device you use; the type of browser and operating system you use; the date and time you access the Site; the address of websites you visit prior to or after visiting our Sites; the number of times you access our Sites; the pages viewed and features you access during your visit to our Sites; how long you viewed each page; responses to advertisements and promotions on the Sites, other websites and mobile applications; Cognia emails you open and links you click within those emails; data regarding your internet service provider or mobile carrier geolocation data (to the extent provided by you or your device); and inferences which we may gather relating to your preferences, attitudes, characteristics or behaviors.
We may collect information about you from your Institution in compliance with applicable laws, by fair means and, where appropriate, with your knowledge or consent including if you are a student, test-taker, employee, or contractor of such Institution. That information may include a student’s name; parents’ names; addresses of students or families; a student’s ID number; a student’s student number; a student’s biometric record; your username and password, or credentials assigned to your Institution or to you by your Institution; other information, such as a student’s date of birth, place of birth and mother’s maiden name, other information that, alone or in combination, is linked or linkable to a specific student that would allow a reasonable person in the school community, who does not have personal knowledge of the relevant circumstances, to identify the student with reasonable certainty; or information requested by a person who the educational agency or institution reasonably believes knows the identity of the student to whom the education record relates.
We may collect information about you from other third-party sources, including from commercially available sources such as data brokers or other companies that collect or analyze information about consumers or users. Examples of information we receive from third-party sources include: (1) demographic information from data brokers and other sources to help anticipate consumer trends and needs; (2) information provided from sources you have authorized to share information with us, either on our Site or via third-party applications, devices, websites, or other digital interfaces; and (3) other similar types of information. We may also gather information from other third parties who maintain their own privacy practices and policies. We may combine information obtained from other sources with information we collect ourselves.
We may use Personal Information we collect to operate our business, including the following:
We may share the information that we collect about you to support our business. In some cases, and for some forms of information (e.g., regulated student information), our use will be limited as required by law. Generally, entities with which we share or disclose information may include the following:
We may share information with our affiliates and subsidiaries, service providers, data processors, third-party contractors, payment processors and others who perform services for us in connection with our Sites, Learning Community, or our businesses, to complete or confirm a transaction or series of transactions or to provide Services to you (e.g., your Institution or your employer, if you work at an Institution). In some cases, as permitted by law, we may share information with our affiliates to market their products and services to you.
We provide Services to Institutions. In connection with that activity, we may exchange information about you, including with your Institution.
We may share information as part of an actual or proposed merger, acquisition or other sale or transfer of all or part of our assets or business. To the extent you register for or purchase a Service online, we may share your information with all the entities you have authorized us to share information with or request information from.
We may disclose information about you to third parties under certain circumstances, such as in connection with illegal activity on the Sites, or to respond to a subpoena, court order or other legal process. We may release information that we collect to law enforcement, government officials, auditors, professional advisors, or third parties as required or permitted by law, to protect our rights and the rights of others, or in our discretion to prevent fraud, harm or loss to you, ourselves or others.
We may include widgets, tool bars, or icons from social media providers on our Sites that allow you to interact or share information with them, and these social media networks may collect information about your browsing on the pages of our Sites. Such collection may occur even when you do not click on or otherwise activate the widget, tool bar, or icon. These and other entities may also collect information about your activities via Data Technologies, discussed above. The privacy policy of the relevant social media network controls the collection, use and disclosure of all information collected by that social media network.
Third parties may collect personally identifiable information about your online activities over time and across different Web sites when you use our Services. We may share information with marketing providers, analytics providers and advertising networks which deliver targeted advertisements to consumers, including advertisements with links to Cognia websites, and which generate related statistics and metrics. These partners may utilize information collected through a variety of Data Technologies to provide advertising placement, customization, auditing, research and reporting for us and other advertisers.
You may make certain choices about how we communicate with you or the information we collect. For example, you may: elect not to provide your information; adjust your device or browsing settings to disable, prohibit or turn off Data Technologies or geolocation or location services features; and adjust your device’s settings regarding the use of advertising identifiers. (Please note that when you adjust settings or delete Data Technologies in one device or browser, those same settings or deletions may not be effective on other devices or browsers.) As of the effective date above, we do not respond to Do Not Track signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party websites. If you choose to limit collection of your information in these ways, certain Site or mobile application features may not function properly, or at all, and certain Services may not be available to you. If you do not want to receive marketing emails from us, you can follow the unsubscribe link provided in those emails.
In certain countries and in certain states, you have specific rights regarding your Personal Information. Subject to certain limitations (such as our legal obligations), you have the right to access, to obtain a copy of, to correct, to opt-out of the sale or sharing, and to delete your Personal Information. You also can limit the means or frequency of certain communications. To exercise your privacy rights, please submit a request to Legal@cognia.org. If the request is submitted on behalf of another person, please provide sufficient information that allows us to verify you are authorized to make the request.
If you created an online account, you can log in to that account to access all or some of the information you previously provided. Subject to applicable law, you may have the right to obtain confirmation of the categories of Personal Information Cognia maintains about you and/or to request access to and receive a copy of information.
If you believe that the information we maintain about you is inaccurate, you may request that we correct or amend the information by contacting us as indicated in the Contact Us section below. In many cases, you may also access your online account or contact your Institution to correct your information, as appropriate. We may limit our response to your requests as permitted by applicable law.
You have the right to request that we delete any of your personal information we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
Please note that in cases of deletion, limited personal information will remain to document the request. The right to access Personal Information may be limited by local law.
You have the right to opt out of the sharing of your data. Cognia may share Personal Information (including name and contact information) in the context of cooperatives managed by third party vendors. If you opt out in accordance with this Privacy Notice, these organizations will not have direct or continued access to your personal information unless you choose to provide it to them directly by responding to an appeal.
To exercise your privacy rights, please submit a request to Legal@cognia.org. In your request, please make clear what Personal Information you would like to review. For your protection, we may need to verify your identity before implementing your request. If you are submitting a request on behalf of someone else, we may ask for additional verification, such as written documentation or other proof of authority. We will try to comply with your request as soon as reasonably practicable, consistent with applicable law.
Although Cognia will make good faith efforts to comply with privacy rights requests, there may be circumstances in which we are unable to provide access, including but not limited to, where the information would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where the information is subject to legal privilege.
If you exercise one of your privacy rights and we are unable to process your request, we will endeavor to provide you with an explanation as to why the request was denied. The explanation will include information on how to appeal, including the relevant regulatory authorities, based on your state or country of residence. All requests for appeal will be reviewed by the Cognia Legal Department (Legal@cognia.org).
If you are a resident of the State of California, pursuant to California Civil Code Section 1798.83 permits you to request certain information regarding our disclosure of your personal information to third parties for their direct marketing purposes during the preceding calendar year. Please contact us at the email provided in “Contact Us” below to make such a request. Additionally, if you are a resident of the State of California under the age of 18 and you interact with our Site, Services or Learning Community, through surveys, or through other communications, you may request that we remove content or information that you have posted to our Site or Learning Community. You may request removal by contacting us at the email provided in “Contact Us” below. PLEASE NOTE that such request or subsequent removal of content does not ensure complete or comprehensive removal of such content or information posted, as, for example, some of your content posted publicly may have been copied or reposted by another user. Your content or information my remain on our servers in some form, while no longer visible nor accessible to other users of our Site, Services or Learning Community.
If an Institution is providing us information relating to children of any age, we rely solely on those Institutions to collect appropriate parental consent, as required. Therefore, we do not knowingly collect any information of children under the age of 13 unlawfully or without parental consent.
Additionally, Cognia does not direct marketing communications to students or individuals under the age of 18. If you believe we have impermissibly collected personal information from someone under the age of 13, please contact us using the information below.
Our Services may contain links to third-party websites, whose privacy practices may be different from Cognia’s. This Privacy Statement does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third-party operating any website or service to which the Services link. Links to other sites do not imply Cognia’s endorsement of the products or services or privacy or security practices of those websites. In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Sites or our Social Media Pages.
We have several different lawful bases for processing your Personal Information including: (a) as necessary to provide a service or information you request; (b) to comply with legal obligations; (c) based on your consent, and (d) in support of our legitimate interests, where those interests are not overridden by your fundamental rights and freedoms. In certain cases, we process Personal Information because it furthers our legitimate business and education-related interests.
This includes:
Cognia is headquartered in the United States and may provide Services in other countries or use global service providers. For this reason, data and your personal information may be transferred to the United States or other locations outside of your state, province, country, or other location where privacy laws may not be as protective as those in your jurisdiction. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities may be entitled to access your Personal Information. We do not process or share the personal data of European Union (EU) or United Kingdom (UK) residents without explicit consent or unless required by law. Our practices are fully compliant with applicable EU and UK data protection regulations. Where required, data transfers will be made subject to the terms of the applicable contract between you and Cognia or with your consent.
If you disclose any Personal Information relating to other people to us, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Statement.
We use administrative, technical and physical security measures designed to safeguard your information against loss, theft, unauthorized use, disclosure or modification. We employ encryption protocols to safeguard all data in transit and at rest. This ensures that even if data is intercepted or compromised, it remains unintelligible and unusable to unauthorized individuals. Additionally, access to user data is strictly controlled following least-privileged access guidelines, with each employee granted specific permissions based on their role and responsibilities.
We regularly conduct security audits and assessments to identify and address any vulnerabilities in our systems. This involves employing advanced intrusion detection and prevention systems, as well as employing firewalls and other network security measures, to mitigate any potential threats. Of course, despite these measures, no network or system is entirely secure, and we cannot guarantee the security of networks and systems we operate or that are operated on our behalf.
Our policy is designed to adhere to applicable data protection and privacy regulations and to minimize the retention of data beyond what is necessary for business purposes.. Personal and sensitive user data is only retained for as long as required to fulfill the purpose for which it was collected or as required by law. Once the data is no longer necessary, we employ a multi-layered approach to securely delete the data from our systems.
If you have any questions or comments about this Notice, please contact us by email at Legal@cognia.org. Cognia, Inc. 9115 Westside Parkway, Alpharetta GA 30009.