개인정보 처리방침

1. Introduction

This Privacy Policy explains how Cognitive Analytics International LLC ("we," "us," or "our") collects, uses, discloses, and protects your personal information when you use our IQ assessment services.

Data Controller:
Cognitive Analytics International LLC
1802 Saint James Place
Houston, TX 77056, United States
Email: [email protected]

2. Information We Collect

2.1 Information You Provide

Data Type	Examples	Purpose
Account Information	Name, email address, password	Account creation and authentication
Demographic Data	Age, date of birth, country	Age-normalized scoring
Payment Information	Billing address, payment method	Processing certificate purchases
Test Responses	Answers, completion time	Calculating IQ scores and generating reports

2.2 Automatically Collected Information

• Device Information: IP address, browser type, operating system, device identifiers
• Usage Data: Pages visited, time spent, test session duration, interaction patterns
• Cookies and Tracking: Session cookies, analytics cookies, preference cookies
• Technical Data: Screen resolution, language settings, time zone

3. How We Use Your Information

We use your personal information for the following purposes:

3.1 Service Delivery

• Administering and scoring IQ assessments
• Generating personalized reports and certificates
• Providing age-normalized results and percentile rankings
• Maintaining your account and test history

3.2 Communication

• Sending test results and certificates
• Responding to customer support inquiries
• Sending service updates and important notices
• Marketing communications (with your consent)

3.3 Improvement and Analytics

• Analyzing usage patterns to improve our services
• Conducting research to enhance test accuracy
• Identifying and fixing technical issues
• Developing new features and services

3.4 Legal and Security

• Preventing fraud and abuse
• Ensuring test integrity
• Complying with legal obligations
• Protecting our rights and property

4. Legal Basis for Processing (GDPR)

For users in the European Economic Area, we process your data based on:

• Contract Performance: Processing necessary to provide our services
• Legitimate Interests: Improving services, preventing fraud, analytics
• Consent: Marketing communications, optional data collection
• Legal Obligation: Compliance with applicable laws

5. Data Sharing and Disclosure

5.1 We Share Data With:

• Payment Processors: Stripe, PayPal for secure payment processing
• Email Service Providers: For sending test results and communications
• Cloud Hosting: Secure servers for data storage and processing
• Analytics Providers: Google Analytics (anonymized data)

5.2 We Do NOT:

• Sell your personal information to third parties
• Share your test results without your consent
• Use your data for purposes other than stated in this policy
• Share identifiable information with advertisers

5.3 Legal Disclosures

We may disclose your information when required by law, court order, or to:

• Comply with legal processes
• Protect our rights and property
• Prevent fraud or security threats
• Protect user safety

6. Data Security

We implement industry-standard security measures to protect your data:

• Encryption: SSL/TLS encryption for data transmission
• Secure Storage: Encrypted databases with access controls
• Authentication: Strong password requirements and secure login
• Monitoring: Regular security audits and vulnerability assessments
• Access Control: Limited employee access on a need-to-know basis

7. Data Retention

We retain your personal information for as long as necessary to provide our services and comply with legal obligations:

• Account Data: Until account deletion or 3 years of inactivity
• Test Results: Retained for verification purposes (minimum 7 years)
• Payment Records: 7 years for tax and accounting purposes
• Marketing Data: Until you unsubscribe or opt-out

8. Your Privacy Rights

8.1 All Users

• Access: Request a copy of your personal data
• Correction: Update inaccurate or incomplete information
• Deletion: Request deletion of your account and data
• Opt-Out: Unsubscribe from marketing communications

8.2 Additional Rights (GDPR/CCPA)

• Data Portability: Receive your data in a structured format
• Restriction: Limit how we process your data
• Objection: Object to processing based on legitimate interests
• Withdraw Consent: Revoke previously given consent
• Non-Discrimination: Equal service regardless of privacy choices

To exercise your rights, email us at: [email protected]

9. Cookies and Tracking Technologies

9.1 Types of Cookies We Use

• Essential Cookies: Required for site functionality and security
• Analytics Cookies: Help us understand how users interact with our site
• Preference Cookies: Remember your settings and preferences

9.2 Managing Cookies

You can control cookies through your browser settings. Note that disabling essential cookies may affect site functionality.

10. International Data Transfers

Your information may be transferred to and processed in countries other than your own. We ensure appropriate safeguards are in place:

• Standard Contractual Clauses (EU-approved)
• Privacy Shield Framework (where applicable)
• Adequate data protection measures

11. Children's Privacy

Our services are not intended for children under 16. We do not knowingly collect personal information from children. If we discover we have collected data from a child under 16, we will delete it immediately.

Users aged 16-17 must have parental or guardian consent to use our services.

12. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies.

13. Changes to This Policy

We may update this Privacy Policy periodically. We will notify you of material changes via:

• Email notification to registered users
• Prominent notice on our website
• Updated "Last Modified" date at the top of this policy

Continued use of our services after changes constitutes acceptance of the updated policy.

14. California Privacy Rights (CCPA)

California residents have additional rights under the California Consumer Privacy Act:

• Right to know what personal information is collected
• Right to know if personal information is sold or disclosed
• Right to opt-out of the sale of personal information (we do not sell data)
• Right to deletion of personal information
• Right to non-discrimination for exercising privacy rights

15. European Privacy Rights (GDPR)

If you are in the European Economic Area, you have rights under the General Data Protection Regulation, including those listed in Section 8.2 above.

You also have the right to lodge a complaint with your local data protection authority.

16. Contact Us

For privacy-related questions, concerns, or to exercise your rights, contact us: