Privacy Policy

Privacy Policy

As of November 24, 2025 Cognitus Consulting LLC has been acquired by International Business Machines Corporation (“IBM”) and will be integrated into the IBM organization. This policy sets out how Cognitus, an IBM Company (“Cognitus”) handles your personal information if you’re a Cognitus user or visitor to our sites. If you have any questions about our privacy practices or how we have been managing your personal information, please contact our privacy officer at legalteam@cognitus.com 

Introduction

It is Cognitus policy to respect your privacy regarding any information we may collect while operating our website. This Privacy Policy applies to *.cognitus.com (hereinafter, “us”, “we”, or cognitus.com, cognitusconsulting.com). We respect your privacy and are committed to protecting personally identifiable information you may provide us through the Website. We have adopted this privacy policy (“Privacy Policy”) to explain what information may be collected on our Website, how we use this information, and under what circumstances we may disclose the information to third parties. This Privacy Policy applies only to information we collect through the Website and does not apply to our collection of information from other sources.

This Privacy Policy, together with the Terms and conditions posted on our Website, set forth the general rules and policies governing your use of our Website. Depending on your activities when visiting our Website, you may be required to agree to additional terms and conditions.

Where we provide products, services, or applications as a business-to-business provider to a client, the client is responsible for the collection and use of personal information while using these products, services, or applications. This collection and use is covered by the client’s privacy policy, unless otherwise described. Our agreement with the client may allow us to request and collect information about authorized users of these products, services, or applications for reasons of contract management. In this case, this privacy statement, or a supplementary privacy notice, applies.

Personal Information We Collect and Use

This section describes the various types of information that we collect and how we use it.

It includes information on Cognitus Websites, Marketing, Contractual Relationships, Support Services, Protecting You and Cognitus, Cognitus Locations, Recruitment and Former Employees, Conducting our Business Operations, Cookies and Similar Technologies, and Children.

The information that we collect and use may include profile information, interactions on webpages, marketing preferences, information to investigate malicious activities, recordings or transcripts of your conversations with us for support purposes, information to improve our business operations, and more.

Websites and Visitors

Our websites offer ways to communicate with you about us, our products, and services. The information that we collect on websites is used to provide you with access to the website, to operate the website, to improve your experience, and to personalize the way that information is provided to you. If you visit our websites without logging in with an account, we may still collect information that is connected to your website visit.

Links to External Sites

Our Service may contain links to external sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy and terms and conditions of every site you visit.

We have no control over, and assume no responsibility for the content, privacy policies or practices of any third-party sites, products or services.

For more information on the technologies that we use to collect website information, and setting your preferences, see the section on Cookies and Similar Technologies.

Learn more:

  • We collect information about your use of our websites, such as:
  • the webpages you view,
  • the amount of time you spend on pages,
  • the website URL that referred you to our pages,
  • your geographic information derived from your IP address,
  • and any hyperlinks you select.

We use this information to improve and personalize your experience with our websites, provide you with content that you may be interested in, create marketing insights, and to improve our websites, online services, and related technologies.

  • We also collect the information that your browser or device automatically sends, such as:
  • your browser type and IP address,
  • operating system, device type, and version information,
  • language settings,
  • crash logs,
  • account information (if signed in),
  • and passwords.

We use this information to provide you with access to our webpages, improve the webpage view on your device and browser, adapt to your settings and language, and adapt content for relevancy or any legal requirements for your country. We also use this information to comply with system and network security requirements, and to provide support. For more information see the sections detailing Support Services and Protecting You and Cognitus.

We also provide platforms and forums that enable online sharing, support, and collaboration among registered members. Any information that you submit to these platforms may be made available to others on the internet, or removed by us, as covered in the platform privacy notice or terms. We are not responsible for any content that you make available through your use of our products or services.

We prepare reports on the use of our websites to derive insights into trending topics and general market knowledge. These reports may be provided to third parties with details on how users interacted with or showed interest in the third-party products or services that were presented on our websites.

We accept no responsibility for the content provided on, or privacy practices, of third-party websites or applications.

Marketing

Subject to your preferences, we use the information that we collect to communicate with you about relevant products, services, and offerings. We also use this information to personalize your online experience with our content and advertisements and to develop internal marketing and business intelligence.

Learn more:

  • We use information that we collect for marketing purposes. This may include information:
  • Collected directly from you through your interactions with Cognitus, such as attendance at events or submission of online registration forms,
  • Received from third-party data providers, such as event organizers whose events we sponsor
  • Collected on our websites or from your interactions with Cognitus emails and content, including content on third-party sites. For more information on the technologies that we use to collect this information, see the section detailing Cookies and Similar Technologies.

Subject to your preferences, we may use this information to market to you regarding Cognitus products, services, and offerings. For example, we may:

  • Contact you by using email, telephone, or postal mail
  • Personalize your experience with Cognitus products and services, such as sharing more relevant content or pre-filling registration forms on our websites.
  • Deliver targeted advertisements on third-party websites based on information we or authorized third parties collect about your interactions with Cognitus websites, our content, emails, or, in select geographies, activity linked to your hashed email address.

To set or update your marketing communications preferences, you can submit an opt-out request by using our contact us form, select Unsubscribe at the end of each marketing email or by emailing marketing@cognitus.com directly if you wish to unsubscribe and we will remove you from all Cognitus’ marketing communications. 

To review or set your preferences regarding the information that we collect about you online on our websites, select your choices in the Cookie consent manager upon entry to the website.

We also use this information to develop marketing and business intelligence, which is essential for our business operations. For example, we may:

  • Combine the information we collect to better understand your interests and potential business needs,
  • Use aggregated data to measure effectiveness of our marketing campaigns and events, and to proceed to informed business decisions and investments,
  • Aggregate the information that is collected about Cognitus website visitors for the purposes of developing and modelling marketing audiences.

Contractual Relationships

A contractual relationship is created when you order a trial, or a product or service from us. While we mainly provide our products and services to businesses, individuals may also enter into an agreement with us directly as a client. We may collect any information that is reasonably necessary to prepare for, enter, and fulfill, the contractual agreement.

Learn more:

The information collected in a contractual relationship may include the business contact information of the requester, an account ID, and the order details. Information that is required for shipment and payment, for the implementation of services, or to grant access to the product or service may also be collected.

This information may be collected for various purposes, depending on the nature of the products or services, for example, for contractual management and compliance, to provide support, for the improvement or development of our products and services, to contact you for customer satisfaction surveys, and to generate technical and market insights.

The information collected in a contractual relationship is not used for the purposes of marketing and advertising without obtaining consent before processing.

Support Services

When you contact us to request support, we collect your contact information, problem description, and possible resolutions. We record the information that is provided to handle the support query, for administrative purposes, to foster our relationship with you, for staff training, and for quality assurance purposes.

Protecting You and Cognitus

We may collect and use information to protect you and Cognitus from IT security threats and to secure the information that we hold from unauthorized access, disclosure, alteration, or destruction. This includes information from our IT access authorization systems, such as log-in information.

Learn more:

The security solutions we use to protect your information, our infrastructure, and our networks may collect information such as IP addresses and log files. This is necessary for the functionality and utility of security programs to enable the investigation of any potential security incidents and generate insights on security threats.

We may use specialized tooling and other technical means to collect information at access points to, and in, IT systems and networks to detect unauthorized access, viruses, and indications of malicious activities. The information we collect may be used to conduct investigations when unauthorized access, malware or malicious activities are suspected, and to remove or isolate malicious code or content.

Cognitus Locations

When you visit a Cognitus location, we may collect your name or business contact information and, in some cases, information from a government issued ID. This information is collected for access management and to protect the security and safety of our locations and employees.

Learn more:

The information that is collected at our locations is used to issue access badges. We may verify the identity of visitors where legally permissible and, for supplier personnel working on site, a badge with a photo identification may be requested for identification purposes.

Camera supervision and access management are used for reasons of security and safety of our locations, employees, and assets. More information may be available at the Cognitus location.

Recruitment and Former Employees

We are constantly searching for new talent for our organization, and we collect information about job applicants or prospective candidates from several sources. Applicants are referred to the Talent Acquisition Privacy Notice for more information. When an employee leaves Cognitus, we continue to process information that is related to them for any remaining business, contractual, employment, legal, and fiscal purposes, including the management of pensions to the extent handled by Cognitus.

Learn more:

Regarding recruitment, we may look for prospective candidates with the help of recruitment intermediaries and may use publicly available information on social media platforms to identify prospective candidates for a specific function.

When an employee leaves Cognitus, we retain basic information from the former employee about their employment at Cognitus.

Conducting our Business Operations

We collect and use information to improve our business operations, systems, and processes. For example, information may be used to conduct, maintain, audit, and optimize our operations, to protect our assets and employees, for product development, and to defend our rights.

Learn more:

We collect information about our business operations to make informed decisions about the organization, the business, and to report on performance, audits, and trends. For example, we use this information to analyze the costs and quality of our operations. Where possible, this is done by using aggregated information, but may use personal information.

We collect and use information from our business systems, which may include personal information, to:

  • protect or enforce our rights, including to detect fraud or other criminal activities (for example, by using information in payment systems)
  • handle and resolve disputes
  • answer complaints and defend Cognitus in legal proceedings
  • and comply with legal obligations in the countries where we do business

We collect information from the use of our business processes, websites, cloud and online services, products, or technologies. This information may include personal information and is used for product and process development. For example, we may use this information to increase efficiency, decrease costs, or improve services by developing automated processes and tools, or to develop or improve the technologies on which these are based.

Cookies and Similar Technologies

When you visit our websites, cloud and online services, software products, or view our content on certain third-party websites, we collect information regarding your connection and your activity by using various online tracking technologies, such as cookies, web beacons, Local Storage, or HTML5. Information that is collected with these technologies may be necessary to operate the website or service, to improve performance, to help us understand how our online services are used, to determine the interests of our users or to enable access continuity that eliminates repeated form submissions. We use advertising partners to provide and assist in the use of such technologies on Cognitus and other sites.

Learn more:

A cookie is a piece of data that a website may send to your browser, which may be stored on your computer and can be used to identify your computer. Web beacons, including pixels and tags, are technologies that are used to track a user visiting a Cognitus web page or if a web page was copied to another website. Local Shared Objects can store content information displayed on the webpage visited, and preferences. All of these technologies may be used to provide connected features across our websites or display targeted Cognitus advertising (subject to your cookie preferences) on other websites based on your interests. Web beacons may also be used to track your interaction with email messages or newsletters, such as to determine whether messages are opened or links are selected.

Session cookies can be used to track your progression from page to page so that you are not asked for information that you have already provided during the current session, or information that is needed to be able to complete a transaction. Session cookies are erased when the web browser is closed.

Persistent cookies issued by Cognitus expire every 14 months. Cognitus allows cookies issued by vendors on its websites. For cookies issued by vendors, persistent cookie retention periods are covered by the vendor’s privacy policy.

You can use the Cookie Manager to learn more about the online tracking technologies we use and to review or set your preferences regarding the information that we collect about you on our websites. The Cookie Manager is either presented as a notification window when you first visit a webpage or opened by selecting Cookie Preferences in the website footer. The Cookie Manager does not address all types of tracking technologies (for example, email pixels). When using mobile apps, use the options on your mobile device to manage settings.

Blocking, disabling, or rejecting Cognitus cookies may cause services to not function properly, such as in connection with a shopping cart, or block the use of websites or Cognitus Cloud services that require you to sign in. Disabling cookies does not disable other online tracking technologies, but prevents the other technologies from accessing any details stored in cookies.

Our websites offer the possibility to use third-party social media options.  If you elect to use these options, these third-party sites may log information about you, such as your IP address, access time, and referring website URLs. If you are logged in to those social media sites, they may also link collected information with your profile information. We accept no responsibility for the privacy practices of these third-party services and encourage you to review their privacy policies for more information.

For information on cookies and how to remove these technologies by using browser settings, see https://www.allaboutcookies.org/. 

Children

Unless otherwise indicated, our websites, products, and services are not intended for use by children or minors as specified by law in their jurisdiction.

Sharing Personal Information

We may share your personal information internally and externally with suppliers, advisors, or Business Partners for Cognitus’ legitimate business purposes, and only on a need-to-know basis. This section describes how we share information and how we facilitate that sharing.

How We Share Personal Information

When sharing personal information, we implement appropriate checks and controls to confirm that the information can be shared in accordance with the applicable law.

If we decide to sell, buy, merge, or otherwise reorganize businesses in some countries, such a transaction may involve disclosing some personal information to prospective or actual business purchasers, or the collection of personal information from those selling such businesses.

Learn more:

Internally, personal information is shared for our business purposes: to improve efficiency, for cost savings, and internal collaboration between our subsidiaries. For example, we may share personal information such as managing our relationship with you and other external parties, compliance programs, or systems and networks security.

Our internal access to personal information is restricted and granted only on a need-to-know basis. Sharing of this information is subject to the appropriate intracompany arrangements, our policies, and security standards. For more information, see the section titled Legal Basis.

Externally,

  • our business with suppliers may include the collection, use, analysis, or other types of processing of personal information on our behalf. 
  • our business model includes cooperation with independent Business Partners for marketing, selling, and the provision of Cognitus products and services. Where appropriate (for example, when necessary for the fulfilment of an order), we share business contact information with selected Business Partners.
  • we may share personal information with professional advisors, including lawyers, auditors, and insurance companies to receive their services.
  • we may share contractual relationship information with others, for instance, our Business Partners, financial institutions, shipping companies, postal, or government authorities, such as the customs authorities that are involved in fulfillment.
  • We may share personal information with third parties, such as advertising technology partners, data analytics providers and social networks engaged by Cognitus to deliver targeted Cognitus advertisements on their platforms, to aggregate information for analysis, and to track engagement with those advertisements.

In certain circumstances, personal information may be subject to disclosure to government agencies in accordance with judicial proceedings, court orders, or legal processes. We may also share personal information to protect the rights of Cognitus or others when Cognitus believes that such rights may be affected, for example to prevent fraud.

Facilitating International Transfers

Your personal information may be transferred to or accessed by Cognitus subsidiaries and third parties globally. Cognitus complies with laws on the transfer of personal information between countries to keep your personal information protected, wherever it may be.

Information Security and Retention

To protect your personal information from unauthorized access, use, and disclosure, we implement reasonable physical, administrative, and technical safeguards. These safeguards include role-based access controls and encryption to keep personal information private while in transit. We also require our Business Partners, suppliers, and third parties to implement appropriate safeguards, such as contract terms and access restrictions, to protect information from unauthorized access, use, and disclosure. 

Cognitus makes artificial intelligence models and systems available, including large language models (often called LLMs). Cognitus may make such AI models and systems available under separate terms. 

Cognitus’ AI models and systems are designed, trained, validated, and tested on data from publicly available sources that may incidentally contain Personal Information. We have implemented safeguards, processes, and tools to mitigate associated impacts and help address responsible development and deployment of trustworthy AI.

We only retain personal information as long as necessary to fulfill the purposes for which it is processed, or to comply with legal and regulatory retention requirements. Legal and regulatory retention requirements may include retaining information for:

  • audit and accounting purposes,
  • statutory retention terms,
  • the handling of disputes,
  • and the establishment, exercise, or defense of legal claims in the countries where we do business. 

We retain any contractual relationship information for administrative purposes, legal and regulatory retention requirements, defending Cognitus rights, and to manage Cognitus’ relationship with you. The information that is provided in a supplementary privacy notice may provide more detailed information on applicable retention terms.

Your Rights

You may have certain rights when it comes to the handling of your personal information.

The Contact Us page can be used to:

  • ask questions related to this Privacy Statement and privacy practices.
  • submit a complaint to Cognitus if you are not satisfied with how Cognitus is processing your personal information.
  • request access to the personal information that we have on you, or have it updated or corrected. Depending on the applicable law, you may have additional rights concerning your personal information.
  • request to obtain your personal information in a usable format and transmit it to another party (also known as the right to data portability);
  • request to delete the personal information we hold about you;
  • Opt-out of specific personal information processing types, such as targeted advertising

Your rights may be subject to limitations and exceptions resulting from applicable laws. For example, there may be situations where we cannot share certain information that you seek if disclosing this means disclosing information about others. You may also have the right to complain to the competent supervisory authority.

To set or update your marketing communications preferences, you can submit an opt-out request by using our contact us form, select Unsubscribe at the end of each marketing email or by emailing marketing@cognitus.com directly if you wish to unsubscribe and we will remove you from all Cognitus’ marketing communications. 

Legal Basis

In some jurisdictions, the lawful handling of personal information is subject to a justification, sometimes referred to as legal basis. The legal bases that we rely on for the lawful handling of your personal information vary depending on the purpose and applicable law.

The different legal bases that we may use are:

  • Necessary for the performance of a contract with you
    • We rely on this legal basis when we need to process certain personal information, such as your contact details, payment details, and shipment details, to perform our obligations or to manage our contractual relationship with you.
    • Examples: 

      • If you intend to purchase a product or service, we require your business contact information to enter into a contract with you or you may need to create an account to access a purchased product online.

      • When fulfilling a contract, you may need to receive support services, for which we will need to collect your contact information.

      • We need personal information to consider job applicants or manage the pension entitlements of retirees (see the section titled Recruitment and Former Employees).

  • Necessary for the purposes of Cognitus’ or a third party’s legitimate interest 

Legitimate interests relate to being able to conduct and organize business, which includes the marketing of our offerings, protecting our legal interests, securing our IT environment, or meeting client requirements.
Examples:

  • We capture your use of, and interaction with our websites to improve them.
  • We process your account to manage access authorization of our services.
  • Where we have a contractual relationship with the organization that you are working for, we have a legitimate interest to process your personal information used to manage this contract.
  • We process your business contact information (see the section entitled Your Account) in combination with other business-relevant information to tailor our interactions with you and promote our products and services. We may process your contact information together with details of a Cognitus event you attended to develop Marketing and business intelligence.
  • We process the personal information of applicants based on our legitimate interest to source suitable talent (see section entitled Recruitment and Former Employees).
  • We have to keep our general business operations functional. To this end we may, for example, processes the login information of our IT systems and networks, or CCTV footage at Cognitus locations for security and safety purposes.

We may also process personal information where it is necessary to defend our rights in judicial, administrative, or arbitral proceedings. This also falls under the legal basis of legitimate interest in countries where they are not a separate legal basis.

We process personal information for credit protection, which is a specific legal basis under Brazilian law (LGPD) but is also covered under the legal basis of legitimate interest in other countries.

  • Consent 

The processing is based on your consent where we request this.
Example:

  • the optional use of Cookies and Similar Technologies or email of Marketing materials.
  • Legal obligation 

Where we need to process certain personal information based on our legal obligation.

 Example:

  • We may be obliged to ask for a government-issued ID for certain transactions, such as for a financing transaction (see section entitled Contractual Relationship).

Privacy Policy Changes

Cognitus may change its Privacy Policy from time to time, and in Cognitus sole discretion. Cognitus encourages visitors to frequently check this page for any changes to its Privacy Policy. Your continued use of this site after any change in this Privacy Policy will constitute your acceptance of such change.

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