A service of Atoka Tech, Inc., d/b/a Cognatum
This Privacy Policy explains how Atoka Tech, Inc., doing business as Cognatum (“Cognatum,” “we,” “us,” or “our”), collects, uses, discloses, and protects information in connection with your use of cognatum.ai and related subdomains (the “Site”). This Policy covers the Site only. If your organization has entered into an agreement to use the Cognatum product (the “Service”), that agreement and any accompanying Data Processing Agreement govern our handling of data submitted to or processed within the Service, not this Policy.
This Policy is written for a business audience visiting the Site to learn about, evaluate, or request access to Cognatum. It is not directed to consumers, and the Site is not designed for use by children.
1. Information You Give Us
We collect information you choose to submit through the Site, including when you request a demo, request a quote, download a resource, subscribe to updates, or contact us. Depending on the form, this may include:
- Name, work email address, and company
- Job role, industry, and approximate timeline for evaluating the Service
- The content of any message, question, or attachment you send us
- For scoping requests: general information about the size of your organization, the number of people who would use or approve content, and the systems you would need Cognatum to read from
We do not ask for, and you should not submit through the Site, Social Security numbers, government identification numbers, payment card numbers, health information, or other sensitive personal information. If you email us, we retain that correspondence in the ordinary course of business.
2. Information We Collect Automatically
Like most business websites, the Site uses cookies and similar technologies to understand how it is used and to support core functionality. We use Google Analytics 4, which records pages visited, approximate location derived from IP address, device and browser type, and referring site.
2.1 The HubSpot Tracking Code
We load the HubSpot tracking code on Site pages to manage marketing and sales communications. It sets first-party cookies (including hubspotutk, __hstc, __hssc, and __hssrc) that give your visit an identifier and records the pages you view. If you later submit a form on the Site, that browsing history is associated with your contact record, so we can see what you read before you got in touch. The Site separately stores campaign tags from the link you arrived on in a first-party cookie called cg_utm for ninety days.
2.2 Advertising Pixel
The HubSpot tracking code also loads an advertising pixel served from hsadspixel.net. This pixel can be used to build audiences for advertising and retargeting campaigns. If Cognatum runs advertising campaigns using this pixel, the Site's cookie banner will offer a way to decline it, consistent with Section 3 below.
4. How We Use Information
We use the information described above to:
- Respond to your inquiries and schedule or prepare a requested demo or quote
- Send the resource you requested and, if you agreed to receive them, occasional follow-up communications
- Keep a record of the conversation if it continues
- Understand in aggregate how the Site is used, and improve its content and performance
- Detect, prevent, and respond to fraud, abuse, or security incidents
- Comply with our legal obligations
We do not use information submitted through the Site to train or fine-tune any artificial intelligence or machine learning model. See Section 11 for more on how this Policy relates to AI features of the Service.
We do not sell personal information for money, and we do not use it for cross-context behavioral advertising in a way that constitutes a “sale” or “share” under applicable state law, except to the extent the advertising pixel described in Section 2.2 is active and in use, in which case Section 6.2 describes your rights and choices.
5. Legal Bases for Processing (EEA, UK, and Similar Jurisdictions)
If you are located in the European Economic Area, the United Kingdom, or another jurisdiction that requires a stated legal basis for processing, we rely on the following bases:
- We need it to provide you the Services, including to operate the Services, provide customer support, provide personalized features, and protect the safety and security of the Services
- It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services, and to protect our legal rights and interests
- You give us consent to do so for a specific purpose
- We need to process your data to comply with a legal obligation
If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place.
6. Your Privacy Rights
6.1 General Rights
Depending on where you live, you may have the right to: access the personal information we hold about you; correct inaccurate information; delete your information; object to or restrict certain processing; receive a portable copy of information you provided; and, where processing is based on consent, withdraw that consent. To exercise any of these rights, email privacy@cognatum.ai. We will respond within the time required by applicable law and will not treat you differently for making a request. If you are in the EEA or UK and believe we have mishandled your information, you may also complain to your local data protection authority.
6.2 U.S. State Privacy Rights
If you are a resident of California, Colorado, Connecticut, Virginia, Utah, or another U.S. state with a comprehensive privacy law, you may have some or all of the following rights, subject to that state's specific requirements and exceptions:
- The right to know what personal information we have collected about you and how it has been used and disclosed
- The right to delete personal information we hold about you, subject to certain exceptions
- The right to correct inaccurate personal information
- The right to opt out of the “sale” or “sharing” of personal information and of targeted advertising
- The right to limit the use of sensitive personal information (we do not knowingly collect sensitive personal information through the Site)
- The right to non-discrimination for exercising any of these rights
We do not sell personal information for monetary consideration. To the extent the advertising pixel described in Section 2.2 causes information collected through the Site to constitute a “sale” or “share” under the California Consumer Privacy Act, as amended by the California Privacy Rights Act, or an equivalent state law, you can opt out at any time by declining marketing cookies in the Site's cookie banner, sending a Global Privacy Control signal, or emailing privacy@cognatum.ai with the subject line “Do Not Sell or Share.” We will not require you to create an account to exercise these rights, and an authorized agent may submit a request on your behalf where permitted by law.
8. International Data Transfers
Cognatum is based in the United States, and our service providers described in Section 7 process information in the United States and other countries. If you are located outside the United States, your information will be transferred to, stored, and processed in the United States, which may not have the same data protection laws as your home jurisdiction. Where required, we rely on appropriate safeguards for these transfers, such as the Standard Contractual Clauses approved by the European Commission and the UK's International Data Transfer Addendum.
9. Data Retention
We keep information submitted through forms for as long as we have an active conversation or business relationship with you, and afterward for the period necessary to satisfy the purpose for which it was collected, resolve disputes, and comply with our legal and accounting obligations. Aggregate analytics reporting is retained without personal identifiers. Correspondence sent to privacy@cognatum.ai is retained consistent with our records retention practices.
10. Security
We use administrative, technical, and organizational safeguards designed to protect information submitted through the Site, and we require our service providers to do the same. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If we become aware of a breach affecting your personal information, we will notify you and any applicable regulator as required by law.
11. Artificial Intelligence Features
This Policy governs the Site only. Use of the Cognatum product itself is governed by your organization's agreement with us and, where applicable, a Data Processing Agreement, not this Policy. The paragraph below describes the product's AI architecture for transparency; it is not itself a term of this website Policy.
Cognatum's AI engine runs on infrastructure we control. Customer content is not sent to OpenAI, Anthropic, Google, or any other third-party model provider for processing unless specifically directed by you to do so, and then only in accordance with a written agreement with you. We do not use customer data to train or improve our AI models without the customer's explicit authorization, and no customer's approved content is exposed to another customer's environment.
Separate from the product, information you submit through this Site — for example, through a demo, quote, or contact form — is not used to train or fine-tune any AI model. Any chatbot or AI-assisted feature that may appear on the Site in the future will be described in this section before it is deployed, along with how information you provide to it is used.
12. Children's Privacy
The Site is intended for a business audience and is not directed to individuals under the age of 16. We do not knowingly collect personal information from children under 13, consistent with the Children's Online Privacy Protection Act, and more broadly do not knowingly collect personal information from anyone under 16. If we learn we have collected personal information from a child in violation of this Policy, we will delete it. If you believe a child has provided us with personal information, contact us at privacy@cognatum.ai.
13. Third-Party Links
The Site may link to third-party websites, including standards bodies, regulators, and primary legal texts. We do not control those sites and are not responsible for their privacy practices. This Policy applies only to information collected on the Site.
14. Changes to This Policy
We may update this Policy from time to time. When we do, we will post the revised version here with a new “Last Updated” date. If a change materially affects how we handle information already collected, we will provide a more prominent notice, which may include a banner on the Site or an email to individuals with whom we have an active relationship.
15. Contact Us
Questions or requests regarding this Policy can be directed to:
Atoka Tech, Inc., d/b/a Cognatum170 S. Main St., Ste 210
Boerne, TX 78006
Email: privacy@cognatum.ai