This Privacy Policy sets out how Cognata Technologies LLC.’s cloud-based Qooper platform collects and uses information from its customers and other individuals (collectively “you”) who access the Qooper websites (including Qooper.io), Qooper App, Qooper’s Admin Dashboard, or any other Qooper products or services that reference this Privacy Policy (collectively “the Services”, “Services”, “Service”).

We have separate policies for how we process personal data through Qooper web and mobile applications through the end user privacy policy below:

https://qooper.io/user-privacy-policy

1. Privacy Policy

This Privacy Policy details how Qooper collects, uses, and processes your information. You should read this entire Privacy Policy before submitting information to Qooper or using any Services. If you or your organization has negotiated an agreement with Qooper, that agreement may have distinct privacy terms which will take precedence over this Privacy Policy.

If this Privacy Policy changes, the revised Policy will be posted on this website. If Qooper makes any material changes to this Privacy Policy, Qooper may notify you by email (sent to the e-mail address specified in your account) or by means of a Policy on this website. Qooper’s customers may receive change notifications directly from their administrators.

The Services may include links or references to non-Qooper websites, services, materials, or entities (collectively “Third-Party Sites”). This Privacy Policy does not apply to Third-Party Sites unless otherwise indicated. Third-Party Sites are subject to their own privacy policy and you are encouraged to review such policies prior to use of any Third-Party Sites.

2. Information Collected

Qooper collects different types of personal data from the Platform. Users and Organizations may provide personal data through the platform in a number of different ways from sign-up to communications or when uploading content within the Platform.

2.1 Information we collect through our Sites, including contact us forms, resource downloads, email sign-ups, Qooper App and when you become a User, at various points throughout your use of the Services.

2.2 Information users provide directly to Qooper when they use the Platform, including contact information, email, a photo of your choice (optional), first name, last name, current position, organization, and other information requested by The Customer.

Users may choose not to submit the information required to achieve a successful program. In this case, Qooper’s functionality will be limited.

2.3 Information automatically collected from users use of Services, including number and frequency of messages sent, the frequency and the length of meetings, the frequency of the goals, the frequency of the milestones, event engagement, news engagement, learning completion rates and skill areas, meeting notes, feedback frequency and notes, mentoring agreement updates, group discussions.

2.4 Cookies and analytics tools

Our websites use cookies and other tools such as activity tracking to help us analyze the use of our Sites, diagnose technical issues, and provide better functionality and display of our Services. The information includes:

• Technical data such as device data, IP address, browser type
• Usage data such as time spent on sites, pages visited, and links clicked.

2.5 Program Manager’s Log

Qooper’s Admin Dashboard for the program managers collects which admin did matching activity, and published events/news/learning/program steps.

2.6 Our platform does not process sensitive data

Qooper does not allow and does not knowingly solicit or collect, and you should not provide, any information regarding an individual’s financial, medical or health condition or other sensitive or special categories of data.

2.7 Children's Online Privacy Protection Act (COPPA) Privacy Policy

We are committed to protecting the privacy of children who use our services. This privacy policy outlines our practices regarding the collection, use, and disclosure of personal information from children under the age of 13, in compliance with the Children's Online Privacy Protection Act (COPPA).

Parental Rights
Parents have the following rights regarding their child's personal information:
No Requirement for Excessive Information: We do not require a child to disclose more information than is reasonably necessary to participate in an activity.
Review and Deletion: Parents can review their child’s personal information, direct us to delete it, and refuse to allow any further collection or use of the child's information.
Limit Disclosure: Parents can agree to the collection and use of their child’s information without allowing disclosure to third parties, unless such disclosure is integral to the service (e.g., mentoring).

Procedures to Exercise Parental Rights
To exercise your rights, please follow these steps:
Contact our primary operator from “How To Contact Us” section of this agreement
Provide your child's name and the specific request (e.g., review information, delete information).
We will respond to your request within a reasonable timeframe and confirm the actions taken.

3. Use of Information

Qooper collects information to match mentors and mentees successfully, to show program measurements, to show the success rate of mentor-mentee matches and overall health of the program.

The end user data is collected so that program managers can track the activity levels in their programs, detect inactive users, and understand the user activities to ensure the best mentoring experience.

Program manager’s log is collected so that the organization can keep track of which program manager took which action for matching or publishing.

The collected information is solely the property of the Customer and is not shared by any other organization. The Customer can access and export their data any time by contacting Qooper team and requesting an export until such functionality is automated on the platform.

Qooper does not send any emails or marketing materials directly to the end-users of the platform or disclose the end user lists to third parties.

4. Information We Share

• With your Organization and according to their instructions to show the activities in communication, mentoring, engagement and learning to improve the programs and to provide personal attention. However, the Organization does not have access to the content of the communication.
• With other Users within the Platform: If you’re communicating with other users and creating content for them, only the users you share this information with will have access to view the content of the communication, mentoring, and learning.
• Qooper may disclose personal data only to governmental agencies:
  • If required to do so by law, regulation, or court order.
  • To respond to governmental and/or law enforcement requests.
  • To identify, contact, or bring legal action against someone who may be causing injury to or interfering with Qooper’s rights or property.
  • To support any claim, defense or declaration in a case or before any jurisdictional and/or administrative authority, arbitration, or mediation panel.
  • Or in connection with disciplinary actions/investigations.

5. Processing of Personal Data Under GDPR for EU residents

5.1 The information that we collect from EU residents may be transferred to, stored, and processed in the United States and other countries outside the European Economic Area (“EEA”) that do not have the same data protection laws as your jurisdiction. We will only do so in compliance with EU law, such as by including data processing agreements based on the EU Standard Contractual Clauses and, in the case of transfers to the U.S., Qooper’s self-certification to the EU-U.S. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

The parties agree that to the extent applicable, they shall comply with the requirements of the California Consumer Privacy Act (“CCPA”) with respect to consumer “personal information” each party collects and the consumer’s Right to Know, Right to Access, Right to Delete, Right to Opt-Out and Right to Equal Treatment, and the parties agree to update their privacy policies to include required disclosures including addition of a “Do Not Sell My Personal Information” link on the home page of the party’s website.

The parties also acknowledge and agree that all student data is confidential and shall only be published or otherwise released to third parties in compliance with the Family Educational Rights and Privacy Act, 20 U.S.C. § 1232g; 34 C.F.R. Part 99, as amended (“FERPA”).”

6. Security

For the purposes of accessing Qooper, you will be required to use an invite code, your email, and password. You are responsible for the security and confidentiality of your password and login information unless using a Single Sign On Integration.

We conduct information risk assessments and we ensure that our staff understands the importance of protecting personal data. We include both physical security and IT security in our overall data security approach. We are diligent in selecting vendors that process personal data on our behalf so that they also ensure appropriate technical and organizational measures to protect the data. We also integrate privacy in the design of our projects that involve the use of personal data in order to secure the information and implement the aforementioned principles.

We will provide support to Organizations in their duty to notify Users and regulatory authorities, as required by law, when personal data has been stolen, disclosed, altered or infringed by an unauthorized person. If you have questions or concerns regarding this policy or if you are aware of a potential breach, please contact us.

7. Data Retention

Please refer to the Service Level Agreement (SLA) (https://qooper.io/terms-of-service) Exhibit A, Section 5 in Qooper Terms of Service for our policies on data retention and backup.

Qooper maintains end user and program manager data as long as:

• The duration of the agreement.
• Until the Customer requests the deletion of the data.

You have the right to access, and edit, and delete your information through Qooper.

8. Information About International Transfers

When using the platform your personal data may be stored and processed by us in the United States. To provide appropriate safeguards for personal data we receive from the European Economic Area (EEA), United Kingdom (UK), and Switzerland, we are certified under the Privacy Shield framework.

For personal data we receive from the EEA, UK and/or Switzerland, Qooper is awaiting certification with the U.S. Depratment of Commerce under the U.S. Provacy Shield Framework and the Swiss-U.S. Privacy Shield Framework.

If you are one of our customers and the use of our Platform requires Qooper to process personal data falling within the scope of the EU General Data Protection Regulation (GDPR), Qooper’s Data Processing Addendum is here.

9. Your Choices

If you are located in the EEA, UK, or Switzerland you have certain privacy rights recognized under the General Data Protection Regulation (GDPR), for instance the right to request access to information, rectification, or erasure.

This section explains how Qooper assists your Organization in fulfilling your privacy rights established under the GDPR law. We only complete the actions below when they are approved by your organization.

Your Organization controls the information collected when you interact with and within the Platform, and accordingly is the entity responsible for attending to your data privacy rights and defining the legal grounds for processing. To that end your Organization will provide you with its specific privacy policy defining what are your choices and how you can exercise your rights. Once your Organization approves your request, we will support in completing the following actions:

• Right to access, and correct your personal data: You and your Organization may access, or correct, information you have uploaded to the Platform by using the tools within the Platform. If you do not see the tools within the Platform, you should contact your Organization directly. Changes on the Platform take immediate effect on your specific network, but data will be retained by us in our backup systems for a commercially reasonable amount of time, typically 90 days.
• Account closure and right of erasure: If you would like to stop using the Platform, you should contact your Organization. Similarly, if you stop working for or with the Organization, the Organization may suspend your User account and/or delete any information associated with your User account according to its privacy policy. In addition, you can also request to your Organization:
  • Account closure and delete identifiable information: In general, account closure means that your name and other identifiable information (including your photo, if provided) will be deleted and not available to us, your Organization or other Users of the platform - your name will be changed to an “anonymous user”. Your engagement data on communication, mentoring and learning will not be deleted, but those will no longer be linked to you.
  • Deletion of content: Please note that content you create and share is owned by your Organization and may remain on the Platform and be accessible even if your Organization deactivates or terminates your account. In this way, the engagement and content you create on the service is similar to other types of content that you may generate in the course of your involvement in the Organization.

Information viewable by Users within the Platform will be deleted within 30 days upon receiving your request, in any case complete removal of data stored on our backup systems, will happen in a commercially reasonable period of time, typically 90 days.

10. Dispute Resolution Procedure

If you or your organization believes that we are not complying with our privacy policy, or have any issue or concern you can submit a complaint with us and we will respond to you within 45 days. To that end please contact us in writing and provide your identification and contact details, name or domain of your Organization and a complete explanation of your concern.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

In the event that you cannot fully resolve your complaint through the Department of Commerce, it is possible that you may use binding arbitration as a final resort. For more information on how to invoke arbitration under the Privacy Shield Framework, please visit https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

11. Updates To This Policy

We may update this Privacy Policy from time to time. When we update this Privacy Policy, we will revise the “Effective Date” date above and post the new Privacy Policy online, make it available through the Platform, and communicate it to the Organization. The Organization will be responsible for notifying you, and may elect to do so through the Platform, or we will notify you if the Organization instructs us to do so. If you disagree with the changes you should cancel your account by contacting your Organization. See “Your Choices” for more information.

12. Contact Qooper

If you have questions or concerns related to this Privacy Policy or Qooper’s information practices, or, if you are interested in exercising data subject rights you may have under applicable law, please contact Qooper at:

Qooper Mentoring Software by Cognata Technologies, LLC.
Attn: Qooper
332 S. Michigan Ave, Suite 900
Chicago, IL 60604
U.S.A
Or
Email: info@qooper.io