CID-EDU Business Privacy Statement a subsidiary to the Cognitive Institute of Dallas

This CID-EDU Business Privacy Statement was updated on April 1, 2023.

In the course of providing CID-EDU Business (“UB”) services and related services to its corporate, non-profit organization and governmental customers (“Customers”), CID-EDU will receive and have access to personal data of individual users to whom customers grant access (“Users”). For the purposes of this privacy statement, Customers are data controllers and CID-EDU is a data processor. CID-EDU’s processing of User data and the security measures implemented to protect such data are detailed in and governed by a written agreement between CID-EDU and each of its Customers.

As a data processor, CID-EDU will access, store and use the personal data of individual Users solely for the purpose of providing the UB services to its Customers and will process the data as instructed by its Customers.

As data controllers, Customers decide which of their employees or other authorized personnel are given access to the UB services. They do this by designating one or more UB account administrators or group administrators (“Administrator”) who act on behalf of the Customer and have the ability to customize the Customer account, manage individual User accounts, access the UB Insights tool and related reporting features, access the UB Administrator tools, and populate the Customer account with Customer-provided content. Customers are solely responsible for establishing policies for and ensuring compliance with all applicable laws and regulations, relating to the collection of personal information relating to individual Users selected by Customers for accessing the UB services. CID-EDU has no direct relationship with individual Users, who should contact Customers (their employer) for assistance with any requests or questions relating to the processing of their personal information.

For avoidance of doubt, this Privacy Statement does not apply to:

any processing of data for the purpose of marketing the UB service to enterprise and corporate prospects;

any other offerings available at CID-EDU.com separate from the UB services, for which the CID-EDU Privacy Policy is applicable. A User may already have an account with CID-EDU to access CID-EDU’s marketplace educational content, and data processed as a result of the use of the CID-EDU marketplace from a User account is governed by the CID-EDU Privacy Policy.

In the event where CID-EDU makes any material changes to the manner in which it processes User data to provide its services to Customers, it will notify Customers.

CID-EDU Business Privacy Statement

1. Information about Users collected and stored by CID-EDU

When a User is given access to the UB services by the Administrator, a User may set up an individual User account and CID-EDU will collect information provided by the User or the Administrator. The Customer can customize the type of data requested to create an account, which may include the following:

first name, last name, and email address required

photo, areas of interest, job skills, goals, and role (optionally provided by User or Customer)

other personal data, as allowed by the Customer

A unique identifying number is assigned by CID-EDU upon the creation of a User account.

Individual User account information may be set to private or public, as selected by Users. If set to public, the information is searchable via search engines and viewable by anyone, including by other Users and the Customer.

Administrators may assign a User to a group membership.

Customers may select to integrate with UB a Single Sign On (SSO) identity provider to enable Users to log in to UB User accounts without the need to disclose passwords to CID-EDU. Users may log in by providing their individual SSO credentials to the SSO identity provider, which will authenticate them and allow or deny access to the Customer account. SSO identity providers share with CID-EDU a unique cookie ID and authentication “token” information to recognize the User as an authorized user of Customer.

At the option of the Customer, the UB service may enable Administrators and Users to interact with others, including with instructors, teaching assistants, other students, and the Customer, by posting reviews about educational content, sending messages to or chatting with others, posting questions or answers, or posting other content. Posted content is stored by CID-EDU and may be publicly available or viewable by others, including Administrators, Users, or instructors and teaching assistants, depending on where the content is posted.

At the option of the Customer, Administrators may enable the ability to “Share to Slack.” This optional feature allows Users to manually or automatically post a message to the Customer’s own instance of the Slack messaging service. To enable this optional functionality, Customer's Slack administrators must grant CID-EDU the ability to read the full list of public channels, private channels, and users in the Customer’s Slack instance. These lists may include individuals in Customer’s Slack instance who are not UB Users. Slack user lists and channels are briefly cached before being automatically purged from CID-EDU's systems.

CID-EDU stores information relating to the activities of Users as they use and interact with the UB services, such as content viewed or accessed (and information relating to that content); interactions with instructors, teaching assistants, Administrators, and other Users; as well as answers, essays, and other items submitted by Users to satisfy the educational content requirements. This information is linked to a User’s unique account ID and is shared with Customers via the Customer Account reporting tools or upon request of the Customer.

The UB service enables Users to contact the CID-EDU Support Team for assistance or to report a problem, concern, potential abuse or other issues regarding the UB services or other users. CID-EDU may collect and store the User’s name, email address, location, operating system, IP address as well as the User’s activity on the CID-EDU platform and communications with the CID-EDU help desk team. CID-EDU may request additional information from Users in order to resolve any issue reported by a User or by another user.

When a User uses the UB services, CID-EDU collects and stores certain information by automated means: (a) technical information about the User’s computer or wireless device, such as IP address, operating system type and version, unique device ID, browser, browser language, domain, and other operating systems or platform information. This information is collected through the use of server log files and tracking technologies, such as: (i) cookies, which are small files that websites send to a computer or wireless device to uniquely identify a browser or mobile device or to store information in a browser setting; and (ii) other tracking technologies (see below for more detailed information).

IP addresses received from browsers or devices of Users may be used to determine the approximate location of Users.

If a Customer makes purchases via credit card, CID-EDU collects certain data about the purchase (such as name and ZIP code) as necessary to process the order. Customers must provide certain payment and billing data directly to CID-EDU’s payment processing partners, including name, credit card information, billing address, and ZIP code. CID-EDU may also receive limited information, like the fact that Customers have a new card and the last four digits of that card, from payment service providers to facilitate payments. For security, CID-EDU does not collect or store sensitive cardholder data, such as full credit card numbers or card authentication data.

2. Purpose of User Data Processing and Retention Period

CID-EDU processes the information collected about Users and Administrators for the purpose of providing the UB services to its Customers, specifically:

Providing, administering, and facilitating access to the UB services, for Customers and Users, and managing Customer or User account preferences

Fulfilling Customer’s instructions with respect to personal data of Users

Displaying and sending via email notifications to Users for:

Responding to User questions or concerns

Making notifications to Users at the request of the Customer

Sending Users administrative messages and information, including confirmation of account creation, enrollment and progress in courses and related content, and notifications of responses from instructions to User questions

Providing information to Users about available content, new UB service features, and personalized content recommendations, which Users can opt out of at any time

Sending push notifications to User wireless devices to provide updates and other relevant messages, which can be managed from the “options” or “settings” page in the mobile application.

Enabling communications among Users and instructors or teaching assistants

Incorporating feedback into and improving the UB services

Resolving User support requests or claims

Email Preferences

Users can individually opt out of receiving non-transactional emails by: (i) following the unsubscribe instructions provided in the email communication; or (ii) managing User account email preferences. A Customer can also instruct CID-EDU to configure email preference settings for all Users of a Customer.

Retention of Personal Data

CID-EDU will retain the data of Users for as long as instructed by the Customer and no longer than required to serve the purposes of processing. CID-EDU will delete certain or all personal data relating to Users upon request of the Customer. CID-EDU may retain aggregated or anonymized data as set forth below.

Use of aggregated data

In addition, User data is aggregated with other CID-EDU marketplace user data to enable CID-EDU to improve its products and services and develop new products and services, including:

Reviewing and analyzing User browser and wireless device technical information

Reviewing user activity across UB and the CID-EDU marketplace (for example, CID-EDU analyzes trends and User traffic and usage information to identify popular content)

Facilitating the technical functioning of the UB services and CID-EDU marketplace, including to troubleshoot and resolve issues, secure the UB services, and prevent fraud and abuse

Developing a personalized content recommendation engine

When User data is used for the above purposes, it is aggregated and/or anonymized so that no personal data of Users is processed.

3. Cookies and other Tracking Technologies

Like many online platforms, CID-EDU and its analytics vendors use server log files and automated data collection tools, such as browser cookies, pixel tags, scripts, and web beacons. These tools are used for analytics purposes to enable CID-EDU to understand how Users interact with the UB services. CID-EDU and its analytics vendors may tie the information gathered by these means to the unique account ID of Users.

Cookies are small text files placed onto a computer or device while browsing the Internet. Cookies are used to collect, store, and share bits of information about User activities. CID-EDU uses both session cookies and persistent cookies.

A session cookie is used to identify a particular visit to the UB services and collect information about interaction with the UB service. These cookies expire after a short time, or when the User closes their web browser after using the UB service. CID-EDU uses these cookies to identify a User during a single browsing session, such as when you log into the UB services. This helps CID-EDU improve the UB service as well as improve the Users’ browsing experience.

A persistent cookie will remain on a User’s device for a set period of time specified in the cookie. CID-EDU uses these cookies to identify and recognize a specific User over a longer period of time. They allow CID-EDU to:

analyze the usage of the UB services (e.g. what links Users click on) in order to improve our UB offering, test different versions of the UB services to see which particular features or content Users prefer to optimize the UB services provide a more personalized experience to Users with more relevant and recommended content and allow Users to more easily log in to use the UB services.

Persistent cookies include:

preferences cookies to remember information about a User’s browser and settings preferences, such as preferred language. Preference cookies make User experience more functional and customized authentication and security cookies to enable a User to log in or stay logged in and access the UB service, to protect User accounts against fraudulent log-ins by others, and help detect, fight, and protect against abuse or unauthorized usage of User accounts. functional cookies to make the experience of using the UB service better, like remembering the sound volume level selected by the User.

CID-EDU uses tracking technology to: (i) determine if a certain page was visited (e.g. the landing page of an advertisement for UB services that is displayed on third party sites) or whether an email sent by CID-EDU was opened or clicked on by a User; and (ii) to customize the learning experience of individual Users by recommending specific courses and other content. Cookie list

CID-EDU will retain the data of Users for as long as instructed by the Customer. CID-EDU will delete certain or all personal data relating to Users upon request of the Customer. CID-EDU may retain aggregated or anonymized data as set forth below.

Service

Name, Expiration, Purpose

CID-EDU

* Additional cookies may be added, and would have the same functionalities as the ones listed

__cidevst [session] For analytics and testing

__cide_2_v57r 1 year For analytics and testing

__cidevstr 1 year For analytics and testing

access_token 1 month For user authentication

client_id 1 month For user authentication

csrftoken 1 year For user authentication

dj_session_id 1 month For user authentication

seen 30 minutes For experience improvement and customization

cd_firstvisit 1 year For experience improvement and customization

dc_rule_vars 2 years For experience improvement and customization

mute 1 month For experience improvement and customization

playbackspeed 1 month For experience improvement and customization

quality_* 1 month For experience improvement and customization

volume 1 month For experience improvement and customization

ufb_acc 1 year For experience improvement and customization

EUCookieMessageShown 10 years For experience improvement and customization

EUCookieMessageState 15 days For experience improvement and customization

eva [session] For experience improvement and customization

__cide_evid [session] {% trans "For experience improvement and customization"

Google Analytics

_ga 2 years For analytics _gid 24 hours For analytics

_gat 1 minute For analytics

_gat_instructor 1 minute For analytics

_gat_UA-12366301-1 1 minute For analytics

SiftScience

_ssid 13 years For security

Intercom

intercom-lou-* 1 year For experience improvement and customization

intercom-session-* 7 days For experience improvement and customization

Marketo

_mkto_trk 2 years Email and course promotion analytics

Optimizely

optimizelyEndUserId 10 years For analytics and testing

optimizelyBuckets 10 years For analytics and testing

optimizelySegments 10 years For analytics and testing

PerimeterX

_px2 5 days For security

_px3 5 days For security

_pxvid 5 days For security

Zendesk

_help_center_session [session] User support authentication and experience

_zendesk_authenticated [session] User support authentication and experience

_zendesk_shared_session 8 hours User support authentication and experience

_zendesk_cookie 20 years User support authentication and experience

_zendesk_session [session] User support authentication and experience

User Preferences with respect to cookies and other tracking technologies

Users can set their web browser to notify them about the placement of new cookies, limit the type of cookies or reject cookies altogether; if enabled, a User may not be able to use some or all of the features of the UB services (for example, may not be able to log in). General information about cookies and how to disable them can be found at https://cookiepedia.co.uk/all-about-cookies.

Various browsers may offer their own management tools for removing HTML5 LSOs.

Most modern web browsers give you the option to send a Do Not Track signal to the websites you visit, indicating that you do not wish to be tracked. However, there is no accepted standard for how a website should respond to this signal, and we do not take any action in response to this signal. Instead, in addition to publicly available third-party tools, we offer you the choices described in this policy to manage the collection and use of information about you.

4. Sharing User Information

In order to provide the UB services to its Customers, CID-EDU shares data regarding Users with a number of third-party service providers. These third parties are contractually required to use User data solely as directed by CID-EDU for the purpose of providing services to CID-EDU. Administrators of existing Customers are able to access our list of current sub-processors on the left sidebar of this page while logged in to UB.

Instructors who upload content on the CID-EDU platform, as well as their teaching assistants, may receive names and account profile information of Users (excluding email addresses), to enable them to respond to user questions and feedback.

Other service providers of Customer may receive information as instructed by Customer.

To perform its services, CID-EDU leases servers from data centers and uses cloud hosting services on which certain content and User data relating to UB is hosted.

CID-EDU’s help center platform vendor hosts and stores all communications between Administrators or Users and the CID-EDU support team. The help center vendor is contractually required to store and process User related data solely as directed by CID-EDU for the purpose of providing services to CID-EDU. CID-EDU also partners with a chat messaging vendor to provide support to Users and Administrators, to collect feedback, and to display in-app messages for feature announcements or onboarding new users.

CID-EDU shares User information with third-party companies that perform email services to enable CID-EDU to send email communications to Users and to manage email preference settings of Users.

CID-EDU shares User information with third-party companies that perform data analysis services to enable CID-EDU to better understand how Users use the UB service. These companies include Chartio, Google Analytics and Mixpanel. To prevent Google Analytics from collecting information for analytics, a User may install the Google Analytics Opt-Out Browser by clicking here, and may also use Mixpanel’s opt out by clicking here.

Any other sharing of User data is subject to the consent and instructions of Customer.

5. Processing of User Data outside of the EEA

If personal data processed by CID-EDU originates from a User or Administrator in the EEA, CID-EDU will ensure that such processing will only take place if: (a) the non-EEA country in question ensures an adequate level of data protection; (b) the transfer is made pursuant to a Data Processing Agreement (“DPA”) executed between CID-EDU and the Customer and subject to the standard contractual clauses designed to facilitate transfers of personal data from the EEA to all third countries that have been adopted by the European Commission (known as the, “Model Clauses”), which have been incorporated into the DPA.

6. General

Translation for Convenience Purposes Only. In the event that Customer has been provided a translated version of the CID-EDU Business Privacy Statement in a language other than English, that translation is provided for convenience purposes only. The English version of the UB Privacy Statement provided at https://CID-EDU privacy is controlling, and in the event of a conflict between the English version of this Privacy Statement and any translated version, the English version will prevail.