Do Not Sell My Personal Information

California Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA)
Cognitiva Systems Inc.
Effective Date: 8 October 2026
Last Updated: 8 October 2026

YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA).

This page explains:

• What constitutes a "sale" under CCPA
• How Cognitiva uses your personal information
• How to opt-out of data sales
• Your other California privacy rights

WHAT IS A "SALE" UNDER CCPA?

Broad CCPA Definition

Under CCPA, a "sale" means:

"Selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for monetary or other valuable consideration."

Key Point: This is MUCH broader than a traditional commercial sale. It includes sharing data for non-monetary benefits.

What Cognitiva Does

We DO: ✓ License anonymized, aggregated datasets to third parties for monetary consideration

We DO NOT: ✗ Sell identifiable personal information to data brokers
✗ Sell email lists or contact information
✗ Sell individual user profiles
✗ Share data for targeted advertising

COGNITIVA'S DATA PRACTICES

Data Licensing (May Constitute "Sale" Under CCPA)

What We License:

• Anonymized campaign performance datasets
• Aggregated industry benchmarks
• De-identified workflow patterns

Who We License To:

• AI/ML research organizations
• Market intelligence firms
• Technology platform providers
• Academic institutions

What's Anonymized: Per our Privacy Policy Section 8:

• All direct identifiers removed (names, emails, IDs)
• Contextual information minimized
• Re-identification risk assessed and mitigated
• GDPR-compliant irreversible anonymization

Why This May Be a "Sale": Even though data is anonymized and doesn't identify you, CCPA's broad definition may classify licensing anonymized data as a "sale."

What We Share (NOT Sales)

Service Providers (NOT Sales): These are CCPA "service providers" processing data on our behalf:

• AWS, Google Cloud, Vercel (hosting)
• Licensed payment partners (payment processing)
• Resend (transactional email)
• Supabase (portal database)
• Anthropic (chat assistant)

Why Not Sales:

• Contractual restrictions prevent them from selling data
• Processing is for our business purposes only
• CCPA service provider contracts in place

Other Disclosures (NOT Sales):

• Compliance with law (subpoenas, court orders)
• Protection of rights (fraud prevention, legal defense)
• Business transfers (mergers, acquisitions)

HOW TO OPT-OUT

Online Opt-Out Form

Use the form at the bottom of this page to submit your opt-out request. We will verify your identity via email and process your request within 15 business days.

Alternative Methods

Email:
optout@cognitiva.systems
Subject: "CCPA Opt-Out Request"
Include: Your email address and account details

Authorized Agent

You may designate an authorized agent to submit opt-out requests on your behalf:

Requirements:

• Signed permission from you
• Agent verification of authority
• We may contact you directly to confirm

Agent Submission:
Email: optout@cognitiva.systems
Include: Signed authorization, your contact info, agent credentials

VERIFICATION PROCESS

Why Verification Is Needed

To prevent unauthorized opt-out requests, we verify your identity before processing.

Verification Methods

For Account Holders:

1. Submit opt-out request
2. We send verification link to email on file
3. Click link to confirm (within 7 days)
4. Opt-out processed

For Non-Account Holders:

1. Submit opt-out request with email address
2. We send verification email
3. Respond with additional identifying information if needed
4. Opt-out processed

For High-Risk Requests:

• Additional verification may be required
• We may request government ID (redacted)
• We balance security with privacy rights

Timeline

Verification: Within 5 business days
Processing: Within 15 business days of verification
Total: Up to 20 business days

Acknowledgment: We'll acknowledge your request within 10 days
Completion Notice: We'll notify you when opt-out is complete

EFFECT OF OPT-OUT

What Changes

After Opt-Out: ✓ Future data NOT contributed to anonymized datasets
✓ You continue to use CognitivaOS normally
✓ No penalties or fees
✓ No degraded service quality

What Doesn't Change:

• Your subscription and pricing remain the same
• Platform features remain available
• Past anonymized contributions cannot be recalled (already anonymized and distributed)

Feature Limitations

Some AI Features May Have Reduced Accuracy:

• AI models rely on aggregated data
• Opting out reduces data available for your account's personalization
• General platform AI still works, but may be less tailored

Specific Limitations:

• Benchmark comparisons (less relevant without your data)
• Predictive analytics (slightly lower accuracy)
• Industry insights (you won't contribute to aggregates)

Important: Core platform functionality (campaign management, approvals, payments) is NOT affected.

RE-OPT-IN

You Can Change Your Mind

To Re-Opt-In (Resume Data Contributions):

1. Email: optout@cognitiva.systems
   Subject: "CCPA Re-Opt-In Request"

2. Include: Email address, account ID

3. We'll confirm and resume data contributions

Timeline: Within 15 business days

Effect: Future data will be contributed to anonymized datasets (past opt-out period remains opted-out)

OTHER CALIFORNIA RIGHTS

CCPA Rights Beyond Opt-Out

Right to Know:

• What personal information we collect
• Sources of information
• Purposes of collection
• Categories of third parties we share with
• Specific pieces of information we have about you

How to Exercise: privacy@cognitiva.systems with "CCPA Right to Know" subject

Right to Delete:

• Request deletion of your personal information
• Exceptions apply (legal obligations, fraud prevention)

How to Exercise: privacy@cognitiva.systems with "CCPA Right to Delete" subject

Right to Correct:

• Correct inaccurate personal information

How to Exercise: Account settings or privacy@cognitiva.systems

Right to Limit Use of Sensitive Personal Information:

• We collect sensitive personal information as defined by the CCPA/CPRA (government ID, tax ID and bank account details) to verify identity, handle tax and automate creator payouts through our licensed payment providers, and use it only for those purposes. You can ask us to limit its use to those purposes.

Right to Non-Discrimination:

• No denial of service for exercising rights
• No different pricing (unless reasonably related to value)
• No different service quality

UNDERSTANDING "SALE" VS. "SHARING"

CPRA Distinguishes Two Concepts

Sale (CCPA):

• For monetary or other valuable consideration
• Cognitiva's data licensing = potential "sale"

Sharing (CPRA):

• For cross-context behavioral advertising
• Cognitiva does NOT do this

Important: We do NOT engage in cross-context behavioral advertising. Your opt-out request addresses data licensing (potential "sale"), not advertising (we don't do targeted ads).

MINORS (UNDER 16)

Special Protections

Children Under 13:

• May NOT use our Services
• We do not knowingly collect data from children under 13

Teens 13-15:

• May NOT use our Services (our Terms require 18+)
• If we learn a user is 13-15, account is terminated

Teens 16-17:

• May NOT use our Services (our Terms require 18+)
• California residents 16-17 have opt-in right (not applicable since we don't serve under-18)

Enforcement:

• Age verification on signup (self-certification)
• Termination if underage use discovered

ANNUAL DISCLOSURE

CCPA §1798.100 Disclosure

Personal Information Collected (Last 12 Months):

Collected for verification and payouts, never sold:

• Sensitive personal information (CPRA definition): government ID, tax ID and bank account details, used only to verify identity, handle tax and automate creator payouts (see Right to Limit Use above)
• Biometric information is processed by our identity-verification provider during creator verification and is not retained by Cognitiva

Not Collected:

• Health information
• Sexual orientation
• Precise geolocation

Categories of Third Parties:

• Service providers (AWS, licensed payment partners, etc.) - NOT sales
• Data licensees (for anonymized datasets) - Potential "sale"

Business Purposes:

• Providing Services
• Security and fraud prevention
• Debugging and error correction
• Internal research (product improvement)

CONTACT INFORMATION

CCPA-Related Inquiries

General CCPA Questions:
Email: privacy@cognitiva.systems
Phone: +1 212-220-8418

Opt-Out Requests:
Email: optout@cognitiva.systems
Online Form: the form on this page

Right to Know Requests:
Email: privacy@cognitiva.systems
Subject: "CCPA Right to Know Request"

Right to Delete Requests:
Email: privacy@cognitiva.systems
Subject: "CCPA Right to Delete Request"

Authorized Agent Inquiries:
Email: privacy@cognitiva.systems
Subject: "CCPA Authorized Agent"

CALIFORNIA ATTORNEY GENERAL

File a Complaint

If you believe your CCPA rights have been violated:

California Attorney General
Privacy Unit
Website: https://oag.ca.gov/contact/consumer-complaint-against-business-or-company
Phone: (916) 210-6276

FREQUENTLY ASKED QUESTIONS

Q: Will opting out cost me money or degrade my service?

A: No. CCPA prohibits discrimination for exercising your rights. Your subscription price and service quality remain the same.

Q: What happens to data you've already collected about me?

A: Opt-out applies to future data only. Past anonymized data has already been aggregated and cannot be "un-anonymized" or recalled.

Q: How is this different from GDPR rights?

A: GDPR gives you stronger rights (e.g., deletion of anonymized data in some cases). CCPA opt-out is specific to "sales." You can exercise both GDPR and CCPA rights.

Q: Can I opt-out for my entire organization?

A: Authorized account administrators can submit opt-out requests on behalf of their organization. Contact privacy@cognitiva.systems for enterprise opt-out.

Q: What if I'm not a California resident?

A: You may still request opt-out, but CCPA rights specifically apply to California residents. See our Privacy Policy for general opt-out rights.

Q: Do you sell data to advertisers?

A: No. We license anonymized datasets to AI/ML organizations, not advertisers. We do NOT engage in targeted advertising.

Q: How do I know my opt-out request was processed?

A: You'll receive email confirmation when your opt-out is complete. You can also email optout@cognitiva.systems to check status.

UPDATES TO THIS PAGE

Last Updated: 8 October 2026

We may update this page to:

• Reflect changes in California law
• Clarify our practices
• Improve user experience

Notification:
Material changes will be announced with 30 days notice via email.

RELATED POLICIES

Full Privacy Policy: cognitivasystems.com/legal/privacy-policy
Terms of Use: cognitivasystems.com/legal/terms-of-use
Cookie Policy: cognitivasystems.com/legal/cookie-policy

END OF DO NOT SELL MY PERSONAL INFORMATION PAGE

For California Residents
CCPA/CPRA Compliant
Version: 3.0
Last Updated: 8 October 2026