Privacy Policy
Version: V1.0.2
Last Updated: Sep 8, 2023
Effective: Sep 8, 2023
The privacy of your data is important to Cogleap. The purpose of this Privacy Policy is to describe how Cogleap Center Achievement Inc. and our subsidiaries (collectively, "Cogleap", "we", "our", or "us") collect, use, and share information about you when you access or use our online interfaces (e.g., websites and mobile applications) owned and controlled by us, including but not limited to Focus Success APP (collectively referred to hereafter as our "Services"). Cogleap Center Achievement Inc. is a Delaware corporation with a principal place of business at 950 Roosevelt #201, Irvine, CA 92620.
Please read this Privacy Policy carefully to understand what we do. By continuing to use our Services, you agree to the terms of this Privacy Policy. If you do not understand any aspects of our Privacy Policy, please feel free to contact us at consumer@cogleap.com.
This Privacy Policy covers information we collect from you through our Services. In order to access certain features of our Services, you may need to submit, or we may collect, "Personal Data" (i.e., information that can be used to identify you and which may also be referred to as "personally identifiable information" or "personal information"). Personal Data can include information such as your name, email address, IP address, and device identifier, among other things. You are responsible for ensuring the accuracy of the Personal Data you submit to Cogleap. Inaccurate information may affect your ability to use the Services, the information you receive when using the Services, and our ability to contact you. For example, your email address should be kept current because that is one of the primary manners in which we communicate with you.
Cogleap collects data from you through our Services. Some of the data is given by you directly. Other data we get is automatically collected by us when you interact with, use, and experience our Services. We gather the following types of information about users:
● Usage Data. We collect and log Internet or other electronic network information (e.g., IP address and login time) on how you access and use Cogleap Services, for example, the act of browsing our websites or editing a child's daily health record in our application.
● Device Information. We collect and log the unique identifiers of your device (e.g., MAC address) when you use our mobile applications. We use the information to identify your device and push important notifications of our Services to it if you allow such notifications. We may also collect information about the operating system on your device (e.g., iOS, Android).
● Cookies: We use cookies when you use our Services to make our website and Services work properly. A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It usually includes an anonymous unique identifier and cannot retrieve any other data from your device. We use cookies and similar technologies to facilitate functions such as user authentication, remembering user preferences, and understanding how users use our Services.
When you use our mobile applications, we may collect the following information with your explicit consent:
● Photos: Cogleap may access your photos when you need to add pictures (e.g., adding a profile picture to your account or editing your child's health record) via camera capture or on-device photos.
● Account Registration. If you register for an account of our Services, you may be required to provide us with certain Personal Data such as your name, phone number, and email address. You may also voluntarily provide us with additional Personal Data.
● Child Health Information. Some of our services feature keeping track of your children's daily mental health. Thus, we collect and store your children's certain physical and mental health information, such as daily nutrition intake, bedtime, and sleep disturbing factors, which is directly provided by you using our Services.
● Surveys and Assessments. We may receive Personal Data when you or your children complete a brief survey or a psychological self-report assessment using our Services.
3.1 Application self-starting instructions
3.1.1 In order to ensure that this application can play music normally when it is closed or running in the background, and receive check-in reminder information and evaluation/training/course push messages pushed by the client, this application must use the application self-starting ability, and there will be a certain frequency. Sending a broadcast through the system to wake up the self-starting behavior of this application is necessary to implement functions and services.
3.1.2 After you click the "Agree" button in the privacy agreement, the application self-launching behavior described in 2.1. will only be performed after obtaining your explicit consent. There will be no self-initiation without your consent.
3.2 Rocket Baby application integration instructions
Case-by-case examples of situations involving the embedding of third-party codes and the transmission of personal information by plug-ins:
3.3.1 Getui
Use the SDK name: com.getui/ Igexin SDK
Application purpose or scenario: for message push
Type/scope of collecting and sharing personal information: device information (device serial number/Android_ID/MAC)
SDK service provider: Merit Interactive Co.,Ltd.
3.3.2 WeChat login
Use the SDK name: com.tencent
Application purpose or scenario: for third-party convenient login
Type/scope of collection and sharing of personal information: list of installed applications, obtain your installed APP information
SDK service provider: Shenzhen Tencent Computer Systems Co., Ltd.
3.3.3 Pasteboard information
Use the SDK name: Flutter
Package name: io.flutter
Application purpose or scenario: account login
Type/scope of collecting and sharing personal information: used to obtain personal historical input content and SMS verification code information in the pasteboard for quick login
SDK service provider: Flutter(Google Inc.)
3.3 Safety instructions
Before you click the "Agree" button of the privacy agreement, the APP or SDK will not have any data interaction with the cloud (except for the web page of the privacy agreement), and will not read or collect any of your information. For your information security, our company has agreed on strict data security and confidentiality obligations with third-party SDK service providers, and these companies will strictly abide by our company's data privacy and security requirements. Unless with your consent, the company will not share your personal information with it.
Collecting your Personal Data set forth above is necessary to perform our obligations under any contract with you or to comply with our legal obligations. In all other cases, provision of the requested personal information is optional, but it may affect your ability to use certain services where your information is needed for those purposes.
● Providing our Services. We use Personal Data provided by you in order to allow you to access and use the Services and in order to provide any information, products, or Services that you request from us.
● Technical Support and Security. We may use your information to provide technical support to you, where required, and to ensure the security of our Services.
● Marketing. We may use your information for our own direct-marketing purposes with your explicit consent.
● Improving the Assessments. Cogleap may use your results of surveys and assessments to establish norms for psychological assessments in order to draw more accurate inferences in later administration of the assessments.
● Scientific Research. By using personal information provided directly through surveys or questionnaires, Cogleap may conduct clinical psychological research related to an interesting research topic or verify the potential efficacy of a novel mental health therapy. Your information will not be sold and Cogleap will use the data solely for research purposes, which may include sharing collected data with trusted third parties, such as academic researchers that work with Cogleap. In these cases, we will de-identify your information before research to ensure that no personally identifiable information will be included. The data collected during research projects may be published in aggregate/anonymous form by Cogleap and/or research partners.
● Disclosures Required by Law. We may be required to disclose your data in response to lawful requests by public authorities, including to meet law enforcement requirements. We may be under a duty to disclose or share your Personal Data in order to comply with any legal obligation, to enforce or apply our Terms of Services and other agreements, to protect our rights, property, or safety, or the protect the rights, property, or safety of others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.
● Disclosure to Acquirers. Cogleap may disclose and/or transfer your Personal Data to an acquirer, assignee or other successor entity in connection with a sale, merger, or reorganization of all or substantially all of the equity, business, or assets of Cogleap to which your Personal Data relates.
Our Services may contain links to and from the websites of third parties other than Cogleap ("Third Party Sites") for your convenience. We do not disclose your Personal Data to these Third Party Sites unless we have a lawful basis on which to do so. If you follow a link to any of these Third Party Sites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any data to these websites.
We keep your Personal Data for no longer than necessary for the purposes for which your Personal Data is collected and processed. The length of time we retain your Personal Data for depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise, or defend our legal rights.
We implement industry standard physical, technical, and administrative security measures to keep your Personal Data confidential and secure, and will not share it with third parties, except as otherwise provided in this Privacy Policy, or unless such disclosure is necessary in special cases, such as a physical threat to you or others, as permitted by applicable law. However, no website, application, or transmission can guarantee security. While we have established and maintain what we believe to be reasonable procedures to protect the confidentiality, security, and integrity of Personal Data obtained through the Services, we cannot guarantee the security of your Personal Data and there is some risk that an unauthorized third party may find a way to circumvent our security systems or that transmission of your information over the Internet will be intercepted.
Cogleap strongly believes in protecting the privacy of children. Any use or access of our Services by anyone under the age of 18 is prohibited, and certain regions may have additional requirements and/or restrictions. In line with this belief, we do not knowingly collect personal identifiable information from children under 18 and no part of our Services is directed to persons under 18 years of age. If you are under 18 years of age, then please do not use or access any of our Services at any time or in any manner. In order to provide certain services related to child mental health, we may collect and store health information of persons under 18 years of age indirectly from their parents and/or legal guardians that are registered users of our Services. We may collect and store results of surveys and self-report assessments directly from children using our Services with verified parental consent. All the data about children set forth above involves no personally identifiable information of children. We will take appropriate steps to delete any personal information of persons less than 18 years of age that has been collected using our Services without verified parental consent upon learning of the existence of such personal information.
If you are a resident of California, please also see our CCPA Notice to learn more about your additional rights regarding our use of your personal information.
From time to time, we may update this Privacy Policy by revising or adding specific instructions, policies, and terms. When the policy is updated, the version date will appear at the top of this privacy policy. If we make material changes, you will be notified here for a period of 30 days based on our last update. We encourage you to periodically review this Privacy Policy to ensure you are familiar with the most current version.
Cogleap welcomes your feedback regarding this Privacy Policy. If you have questions, comments, or concerns about this Privacy Policy, please contact us by email at consumer@cogleap.com or contact us at the following contact details:
Phone: (949)418-8889
950 Roosevelt #201
Irvine, CA 92620
CCPA Notice
Version: V1.0.1
Last Update: Aug 2, 2022
Effective: Aug 2, 2022
This notice addresses the specific disclosure requirements under the California Consumer Privacy Act of 2018 ("CCPA"). It is incorporated into the Cogleap Privacy Policy and applies to personal information about California residents using our Services ("Consumers," "You," or "Your") that we collected over the preceding 12 months. For purposes of the CCPA, personal information means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.
In the event of a conflict between this CCPA Notice and any of our other privacy notices, this CCPA Notice shall control only with respect to the personal information of California residents.
Our Privacy Policy covers our personal information collection and usage more fully. The chart below describes the categories of personal information we have collected from our Consumers in the preceding 12 months, organized into the categories specified by the CCPA.
Category | Examples | Collected |
A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. | YES |
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. | YES |
C. Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | YES |
D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | NO |
E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | YES |
F. Internet or other similar network activity. | Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. | YES |
G. Geolocation data. | Physical location or movements. | NO |
H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | NO |
I. Professional or employment-related information. | Current or past job history or performance evaluations. | NO |
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO |
K. Inferences drawn from other personal information. | Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | YES |
Personal information does not include:
● Publicly available information from government records.
● De-identified or aggregated consumer information.
● Information excluded from the CCPA's scope.
We obtain the categories of personal information listed above from the following categories of sources:
● Directly from our Consumers. For example, from documents that our Consumers provide to us related to the Services for which they engage us.
● Indirectly from our Consumers. For example, through information we collect from our Consumers in the course of providing Services to them.
We may use or disclose the personal information we collect for one or more of the following business purposes:
● To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in order for us to keep a record of your child's daily nutrition intake, we will use that information to calculate the nutrition values and present results to you in the form of charts and figures.
● To provide you with information, products or services that you request from us.
● To provide you with notices concerning our products or services, or events or news, that may be of interest to you.
● To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
● To improve our website and present its contents to you.
● For testing, research, analysis and product development.
● As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
● To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
● As described to you when collecting your personal information or as otherwise set forth in the CCPA.
● To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
For more information about the data we collect and how we use it, please review our Privacy Policy.
If you are a California resident and the CCPA does not recognize an exemption that applies to you or your personal information, you have specific rights regarding your personal information. This section describes your CCPA rights and explains how to exercise those rights.
You have the right to request that we disclose to you free of charge the following information covering the 12 months preceding your request:
● the categories of personal information about you that we collected;
● the categories of sources from which the personal information was collected;
● the purpose for collecting personal information about you;
● the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and
● the specific pieces of personal information we collected about you.
You have the right to request that we delete personal information we collected from you and retained. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records.
To exercise your rights set forth above, you may submit a verifiable consumer request to us by either:
● Contact us at consumer@cogleap.com; or
● Calling us at (949)418-8889.
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
● Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
● Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
California Consumers have the right to opt out of the sale of the Consumer's personal information. We do not sell your personal information to third parties. We do not disclose your personal information to third parties for the third parties' direct marketing purposes.
We may use your personal information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any or all of these communications from us, if any, by either following the unsubscribe instructions provided in any email we send or contacting us using the contact details provided in the 'Contact Information' section in our Privacy Policy. You will still continue to receive service-related messages concerning products and services you have purchased (unless we have indicated otherwise).
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
● Deny you goods or services.
● Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
● Provide you a different level or quality of goods or services.
● Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.