DO NOT SELL MY PERSONAL INFORMATION
California Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA)
Cognitiva Systems Inc.
Last Updated: 15 April 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 (hosting)
- Stripe (payment processing)
- Email providers (transactional emails)
- Support platforms (customer service)
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:
- Submit opt-out request
- We send verification link to email on file
- Click link to confirm (within 7 days)
- Opt-out processed
For Non-Account Holders:
- Submit opt-out request with email address
- We send verification email
- Respond with additional identifying information if needed
- 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):
-
Email: optout@cognitiva.systems
Subject: "CCPA Re-Opt-In Request" -
Include: Email address, account ID
-
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:
- Currently not applicable (we don't process sensitive personal information per CCPA definition)
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):
| Category | Examples | Collected? | Sold or Shared? |
|---|---|---|---|
| Identifiers | Name, email, IP address | Yes | Anonymized only |
| Commercial Information | Campaign data, payment records | Yes | Anonymized only |
| Internet Activity | Browsing, clickstream | Yes | Anonymized only |
| Geolocation | City-level location | Yes | Anonymized only |
| Professional Information | Job title, company | Yes | Anonymized only |
| Inferences | Campaign preferences, behavior patterns | Yes | Anonymized only |
Not Collected:
- Biometric information
- Health information
- Sexual orientation
- Precise geolocation
- Sensitive personal information (CPRA definition)
Categories of Third Parties:
- Service providers (AWS, Stripe, 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: +1 302-217-6601
Opt-Out Requests:
Email: optout@cognitiva.systems
Online Form: [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: 15 April 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: cognitiva.systems/legal/privacy-policy
Terms of Use: cognitiva.systems/legal/terms-of-use
Cookie Policy: cognitiva.systems/legal/cookie-policy
END OF DO NOT SELL MY PERSONAL INFORMATION PAGE
For California Residents
CCPA/CPRA Compliant
Last Updated: 15 April 2026
Opt-Out Request Form