Privacy Policy

1. Controllers of Personal Information. This Data Protection Declaration (“Privacy Policy”) gives you an overview of how Epic Technology Limited (company number 69960443-000) (“Cognitiff”) processes your data. It applies to all websites, apps and other benefits and services offered by Cognitiff.

2. Apps and Websites.

   1. Company Website (Cognitiff.com)

      1. Epic Technology Limited built and designed the company website for the purpose of ensuring online presence. The website is provided by Epic Technology Limited and is intended for use as is.

      2. If you choose to use the website, then you agree to the collection and use of information in relation to this policy. The Personal Information that we collect is used for providing and improving the content of the website. We will not use or share your information with anyone except as described in this Privacy Policy.

      3. Google Analytics

         1. Our website uses Google Analytics with the extension “anonymizeIP,” a web analysis service of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (hereafter: “Google“). This allows IP addresses to be processed by Google in a shortened form in the European Union or in other states, party to the European Economic Area Agreement. Only in exceptional cases your full IP address will be transferred to a Google server in the US and shortened there. Personal references to you are not possible. If collected data includes personal references, this data will be immediately excluded and the personal data will be deleted.

         2. The legal basis for our use of Google Analytics is Art. 6 (1) Sentence 1 Letter f of the GDPR. Google will use collected data to assess your use of our website, compile website activity reports and provide additional services for use of the website and the Internet on our behalf. Processing is performed to analyze and optimize our website.

         3. In addition to your browser settings, you may prevent collection of data generated by cookies on your use of the website (incl. your IP address) and its transfer to and processing by Google by downloading and installing a browser plugin under following link: https://tools.google.com/dlpage/gaoptout. Please see Google’s Privacy Policy for more information about Google’s data collection and processing: www.google.com/policies/privacy.

   2. Atlassian Plugins.

      1. Cloud Plugins.

         1. Data Storage and Facilities. COGNITIFF uses AWS to host its cloud hosted add-on components. COGNITIFF are responsible for provisioning, monitoring and maintaining the AWS infrastructure required to support our Cloud Plugins. Log information is stored on Elastic Cloud hosted on AWS.

         2. Stored Jira Data. Unless specifically highlighted below COGNITIFF do not store our customer data which instead is stored in the Atlassian Cloud Product that the add-on applies to. The data stored in the Atlassian Cloud Product is covered by the Atlassian Cloud Policy which can be found here.

         3. Exceptions for all Cloud Plugins.

            1. Account Data. Our Cloud Plugins store data provided and generated by Atlassian, that are required for license validation, contract administration and communication with the customer instance.

            2. Session Data. Our Cloud Plugins may store data resulting from each customer’s use of the service and is distinguished from Customer Uploaded Data. This data is anonymised. Therefore, we cannot identify the end user this data relates to.

            3. Analytics. We use Google Analytics and to allow us to analyse behavior patterns that ultimately lead to product improvements. It is exclusively used in order to improve our service. It does not contain any Customer Uploaded Data or Operational Data. COGNITIFF only captures the page that is viewed and the referrer along with the tenant identifier. There is additionally individual and organisational data that Google Analytics records, COGNITIFF do not intend to use this data.

            4. Error Logs. Our Cloud Plugins track errors of our Cloud Plugins’ resources executed in the end users’ browsers in real-time. This includes for example AddOnKey, ClientKey, BaseUrl, anonymised TrackingID, error messages and information about the environment such as browser type, browser version and operating system. It is exclusively used in order to improve our service. Errors from JavaScript in our cloud applications are sent to Microsoft App Service to alert COGNITIFF support. The data sent to Microsoft App Service includes organisational data but no individual data.

         4. Data Location. Data is stored in the following AWS Regions us-west-2, eu-west-1, us-east-1

         5. Encryption. We encrypt sensitive data at rest in our database using AES-256.

      2. Server Plugins.

         1. Account Data. COGNITIFF will have access to your Atlassian Product license key and the contact information of the license holder. In addition, Atlassian will have to retain a copy of your contact details and license key of the Atlassian Products for their own records, along with any correspondence you may have with them directly.

   3. Baby Color Tap.

      1. General Terms

         1. Cognitiff built and designed the Baby Color Tap app to be used by babies and young children with parent supervision. This app is provided by Cognitiff and is intended for use as is.

         2. If you choose to use our app, then you agree to the collection and use of information in relation to this policy. The Personal Information that we collect is used for providing and improving the app. We will not use or share your information with anyone except as described in this Privacy Policy.

         3. The terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, which is accessible at Baby Color Tap unless otherwise defined in this Privacy Policy.

      2. Information Collection and Use.

         1. For a better experience, while using our App, we may require you to provide us with certain personally identifiable information. The information that we request will be retained by us and used as described in this privacy policy.

         2. The application uses Microsoft Visual Studio App Center, a third party service for performance monitoring and service optimization. Please refer to the Microsoft Privacy Policy for more details. We collect basic usage data, including events such as “tap”, “app opened”, “app closed”. The event data may include information that describes your session and the technical details of your device.

         3. In the case of an error in the app or a crash we may collect data (“log data”) and information through Microsoft Visual Studio App Center. This log data may include information such as your device model, operating system version, the configuration of the app when utilizing our app, the time and date of your use of the app, and other technical statistics.

         4. The app is hosted on the the Google Play Platform. Please review the privacy policy of Google Play Apps.

      3. Children’s Privacy.

         1. We do not contact or collect information from children and minors. However, if you believe that we have inadvertently collected such information, please contact us to promptly obtain the consent of the parents/guardians or erase the information.

         2. We advise reading this privacy policy, since by allowing your children to use our app you are agreeing to this privacy policy on their behalf. If you disagree, please do not allow your child to use our app.

      4. System Events.

         1. Device and access data arises each time you use an online or mobile service. This technical data arises and will be processed in order to provide the functions and content offered and to display them on your device. Device and access data includes the following categories:

            1. General device information, such as information on the device type, operating system version, configuration settings (e.g. language settings, system authorizations), information on internet connection (e.g. name of the mobile data network, connection speed) and on the app used (e.g. name and version of the app).

            2. Identification data (IDs), such as session IDs, cookie IDs, unambiguous device ID numbers (e.g. Google advertising ID, Apple Ad ID), third party account IDs (if you use social plug-ins or social logins or pay by PayPal) and other common internet technologies, to facilitate recognition of your web browser, your device or a particular app installation.

            3. Access data automatically transmitted by apps and web browsers whenever you access web servers and databases (within the framework of so-called HTTP requests). This is standardized information on the required content (such as the name and file type of a retrieved file) as well as further information on server access (such as amount of data transferred and error codes), on your device (e.g. device type, operating system, software versions, device identifications, IP address, the site previously visited and the time of access).

         2. The system data will be stored and processed on the AWS Cloud Platform (Amazon Web Services EMEA SARL, 5 RUE PLAETIS, L-2338 LUXEMBOURG R.C.S. LUXEMBOURG: B 186284).

3. Data Retention. User data is retained as long as it is necessary to provide the service. Data is deleted from our records when it is no longer needed within a reasonable time-frame. You may request that your data be removed from our servers by contacting us.

4. **Changes to This Privacy Policy.**We may update our Privacy Policy from time to time. Thus, you are advised to review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Policy on this page. These changes are effective immediately after they are posted on this page.

5. Security. We value your trust in providing us your Personal Information, thus we are striving to use commercially acceptable means of protecting it.

6. Contact Us. If you have any questions or suggestions about our Privacy Policy, do not hesitate to contact us.