FAIR PROCESSING NOTICE AND CONSENT
Cognizant Worldwide Limited and its affiliated companies located across the world ("Cognizant", "we", "us", "our") is committed to protecting the privacy of individuals who register to use our Services (as defined below) and individuals who register to attend our corporate events. This Fair Processing Notice ("Notice") describes Cognizant’s privacy practices in relation to our community forums, blogs, event planning and related notices, related services and applications (collectively, the “Services”) as well as individuals’ choices regarding use, access, and correction of personal information provided to Cognizant in conjunction with the Services. Cognizant stores and processes some of data that it collects in connection with the Services with the assistance of third party vendors. For example, Cognizant uses certain cloud based platforms offered by Salesforce.com, Inc. (“Salesforce”), such as “Cognizant Connections” (an online social platform for clients) and “Pardot” (a "software as a service" marketing automation solution). You are being asked to read and accept the terms of our data collection and processing practices in connection with the Services, as set out in this Notice.
To learn more about our practices, please see below.
- What personal data is collected and processed?
- Website Navigational Information
- How will your personal data be used?
- Who will have access to your personal data?
- How will we store your personal data?
- What rights do you have in relation to your personal data?
- Information about Cognizant Connections
1. What personal data is collected and processed?
When you seek information about the Services, participate on Cognizant Connections, or register for an event, Cognizant requires you to provide us with your personal contact information, including name, company name, address, phone number, and email address (“Required Contact Information”). We may also ask you to provide additional information, such as company annual revenues, number of employees, or industry (“Optional Information”). As you navigate our Services, Cognizant may also collect information through the use of commonly-used information-gathering tools, such as cookies and Web beacons (“Website Navigational Information”). Required Contact Information, Optional Information, Website Navigation Information and any other information you submit to Cognizant through the Services is referred to collectively as “Data.”
Below are examples of the Data we may collect about you:
- Identity information such as name, address, gender, personal contact details (including email address and telephone number);
- Employment details such as job title, description of job role, work contact details (including work email address and phone number), work history i.e. previous roles;
- Background information such as professional membership details and interests and preferences in a professional/personal sense which may be deduced from information provided by you; and
- Website Navigational Information which includes standard information from your web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on our website (such as the pages viewed and the links clicked).
We are however firmly committed to protecting your privacy. Therefore we will treat your Data confidentially and will only process and, where relevant, disclose it as set out in this Notice.
2. Website Navigational Information
Cognizant uses Website Navigational Information, which are commonly-used information-gathering tools such as cookies and Web beacons, to collect information as you navigate our website and use the Services. As described more fully below, we and our partners, including Salesforce, use these cookies or similar technologies to analyze trends, administer website and Services, track users’ movements around the site, serve targeted advertisements and gather demographic information about our user base as a whole. This section describes the types of Website Navigational Information we use in connection with our site and Services, and how this information may be used.
The following sets out how Cognizant uses different categories of cookies in connection with the Services and your options for managing cookies’ settings.
|Type of Cookies||Description||Managing Settings|
|Required cookies||Required cookies enable you to navigate the website and use its features, such as accessing “members only” Services. If you have chosen to identify yourself to us, we will place cookies on your browser containing an encrypted, unique identifier. These cookies allow us to uniquely identify you when you are using the site and Services and to process your online transactions and requests.||Because required cookies are essential to operate the site and the Services, there is no option to opt out of these cookies.|
These cookies collect information about how visitors use our website and Services, including which pages visitors generally go to most often and if they receive error messages from certain pages. It is only used to improve how our website and Services function and perform.
From time-to-time, Cognizant engages third parties to track and analyze usage and volume statistical information from individuals who visit its website and use the Services. Cognizant and its third-party partners may also utilize HTML5 local storage or Flash cookies for these purposes. Flash cookies and HTML local storage are different from browser cookies because of the amount of, type of, and how data is stored.
To learn how to opt out of performance cookies using your browser settings click here.
To learn how to manage privacy and storage settings for Flash cookies click here. Various browsers may offer their own management tools for removing HTML5 local storage.
Functionality cookies allow our site to remember information you have entered or choices you make (such as your username, language, or your region) and provide enhanced, more personal features. These cookies also enable you to optimize your use of our site and Services after logging in. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize.
Cognizant uses local shared objects, also known as Flash cookies, to store your preferences or display content based upon what you view on our Web sites and Services to personalize your visit.
To learn how to opt out of functionality cookies using your browser settings click here. Note that opting out may impact the functionality you receive when using our site and Services.
To learn how to manage privacy and storage settings for Flash cookies click here.
b. Web Beacons
Cognizant uses Web beacons alone or in conjunction with cookies to compile information about how Visitors’ and others use its website and interact with us. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you view a particular page or Service tied to the Web beacon, and a description of a website or Service tied to the Web beacon. For example, Cognizant may place Web beacons in marketing emails that notify us when you click on a link in the email that directs you to our website. Web beacons operate to improve our website, Services and email communications to you.
c. Log Files, IP Addresses, URLs and Other Data
As is true of most websites, we gather certain information automatically to analyze trends in the aggregate and administer our website and Services. This information may include your IP address (or the proxy server you use to access the internet), device and application identification numbers, your location, your browser type, your Internet service provider and/or mobile carrier, the pages and files you viewed, your searches, your operating system and system configuration information, and date/time stamps associated with your usage. Due to Internet communications standards, when you visit or use our websites and Services, we automatically receive the URL of the website from which you came and the website to which you go when you leave our website. This information is used to analyze overall trends, to help us improve our website and Services, to track and aggregate non-personal information, and to provide the website and Services. For example, Salesforce uses IP addresses to monitor the regions from which Customers and Visitors navigate to our website. Salesforce also collects IP addresses from Customers when they log into the Services as part of our “Identity Confirmation” and “IP Range Restrictions” security features.
3. How will your personal data be used?
Your personal data will be used by us in connection with the following purposes:
|Service Provision and Internal Processing||Basis for Lawful Processing|
|To provide a service to you, and to provide information on such service.||Cognizant's Legitimate Interests(to deliver and improve our services to you).|
|To confirm, update and improve our customer records to maintain an accurate and rich database.||Cognizant's Legitimate Interests(to deliver and improve our services to you).|
|To respond to any queries or complaints that you raise.||Cognizant's Legitimate Interests(to deliver and improve our services to you).|
|Management of Relationship and Marketing||Basis for Lawful Processing|
|To manage, analyse, understand and develop your relationship with us.||Cognizant's Legitimate Interests(to communicate with and tailor our offer to you).|
|To keep you informed of any of our other/new services and identify and market services that may be of interest to you, where you have chosen to be made aware of this (see further section on Marketing below);||Cognizant's Legitimate Interests (to communicate with and tailor our offer to you) and your Consent|
|To plan and host corporate events, host online forums and social networks in which you may participate.||Cognizant's Legitimate Interests (to communicate with and tailor our offer to you) and your Consent|
|Analytics and Statistics||Basis for Lawful Processing|
|To review the service we provide or have provided to you and carry out analytics and report on customer engagement;||Cognizant's Legitimate Interests (to gather market intelligence).|
|Legal Obligations||Basis for Lawful Processing|
|If we are obliged to disclose information by reason of any law, regulation or court order;||Necessary for Compliance with a Legal Obligation|
|Other||Basis for Lawful Processing|
|For any other purpose to which you agree, or which is not incompatible with the above.||Your Consent|
a. Automated Profiling
Where you provide express consent, we will carry out profiling using automated processing using Pardot to evaluate, analyse or predict preferences. This is to enable us to provide tailored marketing (see section 4b on Marketing below for further details).
From time to time, where we have obtained your prior consent, we may send you information that we perceive may be of interest to you (including in relation to services of our partners, our subsidiaries and our affiliates).
You may receive this information by SMS or e-mail. If, at any time, you prefer not to receive further communications from us in any form (except in connection with information or services that you specifically request), you will have the ability to unsubscribe from such communications by means of a link provided in every e-mail or SMS that is sent to you by us or by contacting us (see section 2 on contacting us).
4. Who will have access to your personal data?
In addition to Salesforce, we may also share your data with the following third parties:
- Our subsidiaries or affiliates, for the purpose of managing our customer relationships, administering our business and to provide you with information which might be of interest to you;
- Entities who may or do acquire any rights in us, for the purpose of a business sale or re-organisation;
- Our advisors, for the purpose of assisting us to better manage, support or develop our business and comply with our legal and regulatory obligations;
- Third party service providers, who need to know the information in order to provide us or you with service (including our third party service providers who process information on our behalf to help run some of our internal business operations including email distribution, data storage, provide information technology and marketing services (including in particular Salesforce.com, Inc.), customer service and for data analytics); and
- Law enforcement and regulatory bodies, in order to comply with any legal obligation or court order.
These parties may be located in the United Kingdom, other countries in the European Economic Area ("EEA"), the United States, India or elsewhere in the world. Different privacy laws may apply in these countries. We only make these arrangements or transfers where we are satisfied that adequate levels of protection are in place to protect any personal data held in that country or that the third party will act at all times in compliance with applicable privacy laws. Where personal data is transferred outside of the EEA, unless the recipient country is deemed to provide an adequate level of protection, we will put in place safeguards to ensure such adequacy. The safeguards we rely on in respect of international transfers are data transfer agreements which incorporate the standard contractual clauses. You may have a right to request any data transfer agreement under which your personal data is transferred, but please note we may redact non-data protection parts of the agreement for reasons of commercial confidentiality.
5. How will we store your personal data?
We invest appropriate resources to protect your personal data, from loss, misuse, unauthorised access, modification or disclosure. Wherever possible, we will ensure that our systems, and procure that our third party service providers systems are appropriately secure for processing your personal data, and that the risks of your personal data being unlawfully used, amended, deleted, lost or stolen are minimized. In particular, we have entered into a contract with Salesforce.com, Inc. to ensure an adequate level of protection for the personal data stored on Pardot.
The personal data that you provide will be retained by us in accordance with applicable laws. However, we will take reasonable steps to destroy or de-identify personal data we hold if it is no longer needed for the purposes set out above, including if you no longer have an active and on-going relationship with us.
6. What rights do I have in relation to my personal data?
You have the right, subject to certain exceptions, to request copies of certain of your personal data within our control and details of how we use that information. If you think any of the personal data we hold about you is inaccurate or no longer required for the original purpose, you may also request it is corrected or erased. From May 25, 2018, you also have the following additional rights:
- Data portability - to the extent that we are relying upon consent as the legal basis for processing, and that personal data is processed by automatic means, you have the right to receive all such personal data in a structured, commonly used and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible;
- Right to restriction of processing - you have the right to restrict our processing of your personal data where:
- You contest the accuracy of the personal data (until we take sufficient steps to correct or verify its accuracy);
- The processing is unlawful but you do not want us to erase the data;
- We no longer need the personal data for the purposes of the processing, but you require the personal data for the establishment, exercise or defence of legal claims; or
- You have objected to processing justified on legitimate interest grounds pending verification as to whether we have compelling legitimate grounds to continue processing.
- Right to withdraw consent - you will also have a right, in certain circumstances, to require us to stop processing your personal data and/or to withdraw your agreement to processing based on 'consent' (including receiving direct marketing (see section 4b above)), but this does not apply where we have other legal justifications to continue processing your data or an overriding legitimate interest i.e. where processing is necessary for the provision of a service.
- Right to object to processing justified on legitimate interest grounds - to the extent that we are relying upon a legitimate interest to process your personal data, then you have the right to object to such processing, unless we can either demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or where we need to process the data for the establishment, exercise or defence of legal claims.
In relation to all of these rights, please contact us , with subject heading "Exercise of Data Subject Right(s)".
If you have a complaint about how we have handled your personal data you may contact us and we will investigate your complaint. You also have the right to lodge a complaint with a supervisory authority (i.e., your local data protection authority) once you have tried to resolve the issue with us.
7. Information About Cognizant Connections
Among its Services, Cognizant offers Cognizant Connections and may also provide bulletin boards, blogs, or networking forums on its website. Any personal information you choose to submit in such a forum may be read, collected, or used by others who visit these forums and sites, and may be used to send you unsolicited messages.
Although Cognizant makes every effort to ensure that participants refrain from these and similar activities, Cognizant is not responsible for the personal information you choose to submit in these forums.
I HEREBY GIVE MY CONSENT
I have read and expressly consent to the processing of my personal data as specifically described in this Notice.