Privacy Policy

This newsletter website is operated by Cogni6 inc. at newsletter.xpert6.ca.

Cogni6 inc. 134, chemin de la Tourterelle, Bureau A Stoneham-et-Tewkesbury (Quebec) G3C 1N4 Canada francis@cogni6.com

For Quebec purposes, the person with the highest authority in charge of personal information protection is Francis Beaulieu, President. You can contact him for any access request, correction request, complaint, withdrawal of consent, or privacy question at francis@cogni6.com.

Depending on how you interact with the site, we may collect the following categories of personal information:

• Contact data: your email address when you subscribe
• Subscription metadata: your language preference, subscription status, signup source, audience tags, and timestamps associated with the subscription confirmation flow
• Email engagement data: open data and click data generated through our email platform when you receive or interact with newsletter emails
• Device and browsing data: pages viewed, referrer, browser, device information, approximate region derived from IP, and ad-conversion events, but only for optional measurement tools after consent where consent is required
• Preference data: your cookie choice, stored locally in your browser for 90 days
• Security and technical logs: limited server or hosting logs needed to keep the site available, secure, and reliable

We do not intentionally collect sensitive personal information through this site, and we do not ask for your name, postal address, or payment information to subscribe.

We collect personal information directly from you when you submit the subscription form, automatically from your browser or device when you use the site, and from our service providers when they confirm subscriptions, opens, clicks, or website events.

We use this information for the following purposes and legal bases:

• To send the newsletter, manage your subscription, and prove your consent: consent
• To measure optional website analytics and Google Ads conversion performance: consent
• To remember your cookie choice and language preference: your request and our legitimate interest in operating the site consistently
• To secure the site, detect abuse, troubleshoot errors, maintain suppression lists, and comply with legal obligations: our legitimate interests and, where applicable, compliance with law

We do not use your information for decisions producing legal or similarly significant effects, and we do not use it for retargeting or social-media tracking.

When you subscribe, your email address is sent to Mailchimp. Our current implementation uses a double opt-in flow, which means your subscription remains pending until you confirm it through the email sent by Mailchimp.

Our newsletter emails are intended to identify Cogni6 inc., include our contact details, and contain a functioning unsubscribe mechanism. You can unsubscribe at any time by using the unsubscribe link in an email or by contacting us.

Mailchimp may record whether an email was opened and which links were clicked. This helps us understand which editions are useful and keep the newsletter relevant. If you do not want open tracking, you can disable remote images in your email client or unsubscribe.

The site uses a limited set of technologies for preferences, security, and optional measurement.

• Strictly necessary technologies: technical hosting or security cookies, the NEXT_LOCALE cookie used to remember your selected language, and local browser storage used to remember your cookie choice for 90 days
• Optional measurement technologies: Google Analytics and Google Ads conversion tags, which are loaded only after you accept optional tags through the banner or the controls on this page
• Email tracking technologies: Mailchimp open and click tracking in newsletter emails

If you refuse or withdraw optional cookie consent, optional website analytics and ad-measurement tags will not load on subsequent page views. You can also block or delete cookies through your browser settings. We do not use social-media pixels or retargeting cookies.

We use service providers that process personal information on our behalf, including:

• Mailchimp (The Rocket Science Group LLC, United States) for email list management and newsletter delivery
• Google Analytics and Google Ads (Google LLC, United States) for optional audience measurement and ad-conversion measurement
• Vercel Inc. (United States) for website hosting and related technical services

We do not sell personal information for money. We do not knowingly use your information for cross-context behavioural advertising, retargeting, or profiling in furtherance of decisions with legal or similarly significant effects.

Because these providers operate from the United States and other jurisdictions, your information may be transferred outside Quebec, outside Canada, and outside the country where you are located. Where a transfer assessment or transfer safeguard is legally required, we seek to use legally recognized mechanisms and contractual protections made available for that transfer. You may contact us to request more information about the safeguards relevant to your situation.

We keep personal information only for as long as necessary for the purposes described in this policy and for related legal, accounting, security, and compliance needs.

• Email address and subscription metadata: while you remain subscribed, plus a limited period afterward to maintain suppression lists, deal with complaints, and document consent or unsubscribe history
• Consent records: for the period reasonably required to prove valid consent and handle legal or regulatory questions
• Cookie-choice record stored in your browser: 90 days unless you clear it sooner
• Analytics and ad-conversion data: for the retention periods configured in the relevant provider tools, or longer only in aggregate or de-identified form where permitted
• Security and technical logs: for the limited period reasonably required to protect, monitor, and troubleshoot the site

If we no longer need personal information, we will delete it or anonymize it where the law permits and appropriate safeguards exist.

We use safeguards appropriate to the sensitivity and volume of the information we hold, including access controls, HTTPS/TLS, reputable processors, and limited access to subscriber data.

No system is perfectly secure. If we have reason to believe that a confidentiality incident involving your personal information has occurred, we will take reasonable steps to reduce the risk of harm and prevent recurrence.

Where Quebec law requires it, we will keep a register of confidentiality incidents and notify the Commission d'acces a l'information du Quebec (CAI) and affected individuals with diligence if the incident presents a risk of serious injury.

Subject to the laws that apply to your situation, you may have the right to request access to your personal information, correction of inaccurate information, deletion, restriction, portability, withdrawal of consent, or information about how your data is used and disclosed.

For people in Quebec and Canada, this includes access and rectification rights, the ability to withdraw consent subject to legal limits, and any portability rights available under applicable law.

For people in the European Economic Area, the United Kingdom, or Switzerland, this may also include the right to object to processing for direct marketing at any time, the right to lodge a complaint with your local supervisory authority, and the right to request information about international-transfer safeguards.

For U.S. residents, if an applicable state privacy law applies to Cogni6 inc. and its thresholds are met, you may also have rights to know, access, correct, delete, port, appeal, or opt out of any sale, sharing, targeted advertising, or certain profiling activities. Because this site does not use retargeting and optional ad-measurement tags are consent-based, refusing or withdrawing optional tags is the main opt-out mechanism for this site.

To exercise any right, email francis@cogni6.com. We may need to verify your identity before acting on your request, and we will respond within the time required by applicable law.

This site and newsletter are intended for a professional audience. They are not directed to children under 13, and we do not knowingly collect personal information from children. If you believe a child has provided us with personal information, contact us so that we can delete it.

If laws in your jurisdiction require a higher age threshold for consent to certain online processing, do not provide personal information unless the relevant consent has been validly obtained.

If you believe we have not handled your information properly, please contact us first at francis@cogni6.com so that we can try to resolve the issue.

You may also complain to the regulator that applies to you, including the Commission d'acces a l'information du Quebec (CAI), the Office of the Privacy Commissioner of Canada (OPC), your European supervisory authority if GDPR applies, or an applicable U.S. regulator such as the California Privacy Protection Agency or your state attorney general where a U.S. state privacy law applies.

We may update this policy from time to time to reflect legal, operational, or technical changes. We will post the updated version on this page and update the "Last updated" date.

If a change materially affects how we handle personal information, we will take reasonable steps to bring it to your attention, for example on the site or by email.

For Quebec purposes, the French version of this policy is intended to govern in case of inconsistency with the English version.