Privacy Policy of Cogram

Personal data is any information relating to an identified or identifiable natural person. A natural person is considered to be identifiable if, directly or indirectly, in particular by means of assignment to an identifier such as a name, an identification number, location data, an online identifier or to one or more special features, the expression of the physical, physiological, genetic, psychological, economic, cultural or social identity of this natural person can be identified.

Data subject is any identified or identifiable natural person whose personal data is processed by the data controller.

Processing is any process carried out with or without the help of automated processes or any such series of processes in connection with personal data such as collecting, recording, organizing, arranging, storing, adapting or changing, reading out, querying, the use, disclosure by transmission, distribution or any other form of making available, matching or linking, restriction, deletion or destruction.

Blocking of processing is the marking of stored personal data with the aim of restricting their future processing.

Profiling is any type of automated processing of personal data that consists of using such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects relating to that natural person’s job performance, economic situation, health, personal preferences, interests, reliability, behavior, location or change of location.

The person responsible or responsible for processing is the natural or legal person, authority, institution or other body that alone or jointly with others decides on the purposes and means of processing personal data. If the purposes and means of this processing are specified by Union law or the law of the Member States, the person responsible or the specific criteria for his naming can be provided for by Union law or the law of the Member States.

The Processor is a natural or legal person, public authority, institution or other body that processes personal data on behalf of the person responsible.

Consent is any expression of will voluntarily given by the data subject in an informed manner and unequivocally for the specific case in the form of a declaration or other clear confirmatory action with which the data subject indicates that they consent to the processing of their personal data.

We, Cogram Inc., 1388 Haight St #1073, San Francisco, CA 94117, United States, (hereinafter “we”), are responsible for processing your personal data pursuant to applicable data privacy law, including Art. 4 (7) GDPR.

You can contact us at info@cogram.com if you have any questions regarding the processing of your personal data.

Cogram may use external third party providers such as cloud infrastructure providers to provide Cogram’s Website or Services. If Cogram uses external service providers, these have been carefully selected by us and commissioned in writing and only process your personal data on Cogram’s behalf. If necessary, we have concluded a processing agreement pursuant to Art. 28 GDPR with third party providers.

We may transfer your personal data to non-EU/EEA countries. Insofar as there is no adequacy decision for such countries according to Art. 45 GDPR, we transfer your personal data subject to appropriate safeguards according to Art. 46 GDPR.

Your personal data will be deleted or blocked as soon as the purpose for processing no longer applies. We will further retain your data if we are legally obliged to do so, especially for tax and accounting purposes. Blocking or deletion of your personal data will also take place if a retention period prescribed by the standards expires, unless there is a need for further storage of the data for the conclusion or performance of a contract.

We do not use automatic decision-making or profiling.

We do not intend for children under 13 years of age to interact with us on Cogram Website or otherwise to store or process personal data of children under the age of 13. No one under age 13 may provide any personal data to Cogram’s Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on Cogram’s Website or through any of its features, register on Cogram’s Website, use any of the interactive or public comment features of Cogram’s Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal data from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at info@cogram.com. California residents under 16 years of age may have additional rights regarding the collection and sale of their personal data.

Each time you access Cogram’s Website, the following personal data is automatically collected and processed:

• IP address of your requesting computer

• browser type, browser version, and language used

• your operating system

• date and time of access of your visit

• name of your access provider

• name of the specific page or file accessed, and the amount of data transferred (access status/http status code)

• website from which your system accesses Cogram’s Website (“referrer URL”)

The legal basis for this processing includes Cogram’s legitimate interest (Art. 6 (1) (f) GDPR). We weighed Cogram’s interest in providing, operating and securing Cogram’s Website against your interest in the confidentiality of your personal data, whereby Cogram’s interest prevails. Without the processing of personal data, the provision of Cogram’s Website is technically impossible. This also applies to its operation and security. In this context, the security of Cogram’s Website also serves your interests.

When you sign up for Cogram’s services, you provide and we process your email address and any information you provide in Cogram’s sign-up form. We require this information to provide Cogram’s Services to you and authenticate you. We also process your name and banking information you provide us with. The legal bases for the processing of your personal data include the initiation of and performance of a contractual relationship in accordance with Article 6 (1) (b) GDPR.

We transfer your personal data to third party service providers, such as cloud services and payment providers.

When you use Cogram’s Service to automate meeting notes we transcribe meetings on your behalf and receive information about those meetings, such as the date and time of the meeting and the attendees’ names, identifiers used in meetings, and email addresses.

Meeting audio is transcribed but no meeting audio or video recordings are stored after transcription. Meeting transcripts are stored and used to generate meeting summaries, notes, and action items. All meeting data is encrypted in transit, and stored in encrypted databases on AWS cloud infrastructure.

When you connect a Google account to Cogram, for example to use Cogram for Gmail or Google Calendar, section III.4 describes how we handle your Google user data.

Our application employs industry-standard security measures, including encryption (both in transit and at rest), secure access protocols, and regular security audits to ensure the integrity and confidentiality of your data. Access to your data is restricted to authorized personnel only, and we implement strict access controls and monitoring to prevent unauthorized access. Strict security measures are in place to protect the confidentiality of your data.

When you have a direct contractual relationship with us, the legal basis for processing your personal data is the performance of a contractual relationship in accordance with Article 6 (1) (b) GDPR.

When your employer or another third party uses Cogram’s Services, we process your personal data as a processor according to Art. 4 No. 8 GDPR. Your employer or the third party using Cogram’s Service is responsible for the collection of your personal data and for ensuring that there is a valid legal basis for doing so.

If you use Cogram’s mobile app and grant location permissions, we access your device’s location data to display the meeting location and enhance meeting context. This location data is processed in real-time and is not stored or shared with third parties. You can disable location access at any time via your device settings. The legal basis for this processing is your consent (Art. 6 (1) (a) GDPR).

This section applies when you connect a Google account to Cogram, for example to use Cogram for Gmail or Google Calendar.

Cogram’s use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy (https://developers.google.com/terms/api-services-user-data-policy), including the Limited Use requirements.