Effective Date: June 29, 2025
Last Updated: June 29, 2025
Thank you for using Cog+!
This Privacy Policy explains how ABS Technologies LLC (“ABS Technologies,” “we,” “us,” or “our”) collects, uses, stores, shares, and protects your information when you use the Cog+ mobile application, website, and related services (collectively, “Cog+” or “the App”). We are committed to protecting your privacy and complying with applicable data protection laws, including the EU General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), the UK GDPR, and other relevant regulations.
1. Information We Collect
We collect the following information when you use Cog+:
1.1. Information You Provide
• Cognitive and Mental Health Data: Responses to cognitive tests (e.g., memory, attention, reasoning tasks) and self-assessed mental well-being scores (optional).
• Account Information: If you create an account, we may collect your email address or other identifiers to manage your profile.
• Consent and Session Data: Confirmation of your consent to this Privacy Policy and technical data such as timestamps and session logs.
1.2. Automatically Collected Information
• Usage Data: Anonymized data about how you interact with the App (e.g., features used, time spent on tasks) to improve functionality.
• Device Information: Limited device data (e.g., operating system, app version) to ensure compatibility and troubleshoot issues.
1.3. Information We Do Not Collect
• We do not collect biometric data, precise location data, or device identifiers (e.g., IP addresses, advertising IDs) unless explicitly authorized by you.
• We do not use third-party analytics or advertising trackers.
1.4. Anonymization and De-Identification
• Data such as cognitive test responses is pseudonymized (linked to a unique identifier, not your name) to protect your identity.
• For research purposes, we may fully anonymize data so it cannot be linked to an individual.
2. How We Use Your Information
We use your information to:
• Analyze your cognitive and mental health performance to generate personalized insights.
• Create and maintain your cognitive and mental health profile within the App.
• Track your performance over time to provide progress reports.
• Share reports with your healthcare provider, if you explicitly request.
• Improve and validate Cog+ through anonymized, aggregated data analysis for research and development.
• Ensure the App’s functionality, troubleshoot issues, and enhance user experience.
• Comply with legal obligations, such as responding to lawful requests from authorities.
3. Legal Basis for Processing
Under GDPR and UK GDPR, we process your data based on the following legal grounds:
• Consent: We process cognitive and mental health data with your explicit consent, which you provide before using the App. You may withdraw consent at any time (see Section 8).
• Legitimate Interests: We process anonymized usage data to improve the App and ensure its functionality, provided this does not override your rights.
• Legal Obligation: We may process data to comply with applicable laws (e.g., court orders).
For users in other jurisdictions, we process data in accordance with local laws, prioritizing your consent and transparency.
4. How We Store and Protect Your Information
We implement robust security measures to protect your information:
• Encryption: Data is encrypted in transit using SSL/TLS and at rest using AES-256 or higher.
• Access Controls: Access to your data is restricted to authorized personnel with a legitimate need, bound by confidentiality agreements.
• Anonymization: Cognitive and mental health data is pseudonymized or anonymized to minimize identification risks.
• Server Location: Data is stored on secure servers in the United States and/or the European Union, depending on your location, in compliance with local data protection laws.
• Security Practices: We conduct regular security audits, vulnerability assessments, and employee training to safeguard your data.
Despite these measures, no system is completely secure. If you suspect a security breach, contact us immediately at support@ai-biosim.com.
5. How We Share Your Information
We do not sell, rent, or share your personal information with third parties, except as described below:
• Healthcare Providers: If you request, we may share your cognitive or mental health report with your designated healthcare provider. We use secure channels (e.g., encrypted email) and obtain your prior consent.
• Service Providers: We may engage trusted third-party processors (e.g., cloud storage providers) to support the App’s functionality. These providers are bound by data processing agreements ensuring compliance with GDPR, CCPA, and other laws.
• Legal Obligations: We may disclose data if required by law (e.g., court orders, public health mandates) or to protect our rights, safety, or property.
• Anonymized Data: We may share fully anonymized, aggregated data for research or statistical purposes, ensuring it cannot be linked to you.
6. Your Privacy Rights
Depending on your location, you have the following rights regarding your personal information:
• Access: View or request a copy of your data.
• Correction: Request corrections to inaccurate or incomplete data.
• Deletion: Request deletion of your data, subject to legal retention requirements.
• Restriction: Restrict or object to certain data processing activities.
• Data Portability: Receive your data in a structured, commonly used format (GDPR-specific).
• Withdraw Consent: Withdraw consent for data processing at any time, without affecting prior processing.
• Non-Discrimination: Exercise your rights without facing discrimination (CCPA-specific).
To exercise these rights, contact us at info@ai-biosim.com or use the App’s privacy settings. We will respond within:
• 30 days under GDPR and UK GDPR (extendable by 60 days for complex requests).
• 45 days under CCPA (extendable by 45 days if notified).
• Other timeframes as required by local laws.
7. Data Retention
We retain your data only as long as necessary to fulfill the purposes outlined in this Privacy Policy or as required by law:
• Account Data: Retained while your account is active and for 1 year after account deletion, unless you request earlier deletion.
• Cognitive and Mental Health Data: Retained for 2 years from the date of collection to enable progress tracking, unless you request deletion.
• Anonymized Data: May be retained indefinitely for research and statistical purposes, as it cannot be linked to you.
• Legal Obligations: Certain data may be retained longer to comply with legal requirements (e.g., tax records).
To request data deletion, contact us at support@ai-biosim.com. We will confirm deletion unless retention is legally required.
8. Consent and Opt-Out Options
• Informed Consent: Before using Cog+, you must provide explicit consent to this Privacy Policy via an in-app prompt. You may withdraw consent at any time through the App’s settings or by contacting us.
• Non-Essential Features: You may opt out of optional features, such as anonymized data sharing for research, in the App’s privacy settings.
• Account Deletion: Deleting your account will stop further data collection and trigger data deletion (subject to Section 7).
Withdrawing consent or opting out does not affect the lawfulness of prior processing.
9. Children’s Privacy
Cog+ is not intended for users under 18 without verifiable parental or legal guardian consent. For users under 13 in the United States, we comply with the Children’s Online Privacy Protection Act (COPPA) by:
• Requiring verifiable parental consent (e.g., via email confirmation or payment verification) before collecting data.
• Limiting data collection to what is necessary for the App’s functionality.
• Providing parents with access to their child’s data and deletion options.
If you believe a minor has used Cog+ without consent, contact us at support@ai-biosim.com for immediate data removal.
10. International Data Transfers
If you are located outside the United States, your data may be transferred to and stored in the United States or the European Union. We ensure compliance with data protection laws through:
• Standard Contractual Clauses (SCCs): Used for transfers from the EU/UK to the US, as approved by the European Commission.
• Adequacy Decisions: Applied where the recipient country is deemed to have adequate data protection (e.g., EU-US Data Privacy Framework, if applicable).
• Safeguards: Encryption and contractual obligations with third-party processors.
11. Third-Party Services
Cog+ may be distributed through third-party platforms (e.g., Apple App Store, Google Play Store), which have their own privacy policies. We are not responsible for the privacy practices of these platforms. Please review their policies before downloading Cog+.
12. Updates to This Privacy Policy
We may update this Privacy Policy to reflect changes in our practices, legal requirements, or the App’s functionality. We will notify you of material changes at least 30 days in advance via:
• In-app notifications.
• Email (if you provided an email address).
• A notice on our website (https://advancedbiosimulation.com).
Your continued use of Cog+ after the updated Privacy Policy’s effective date constitutes your acceptance.
13. Contact Information
For questions, complaints, or to exercise your privacy rights, contact us at:
Email: info@ai-biosim.com
Website: www.advancedbiosimulation.com
For EU/UK users, you may also contact our EU representative:
Email: info-eu@ai-biosim.com
We will respond promptly and in accordance with applicable legal requirements.
14. Entire Agreement
This Privacy Policy, together with our Terms of Use, constitutes the entire agreement between you and ABS Technologies regarding the collection, use, and protection of your information. If any provision of this Privacy Policy is found invalid or unenforceable, the remaining provisions will remain in effect.
By using Cog+, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree, you must not use the Cog+ App.
