Privacy Policy

This Privacy Policy describes how we collect and use your personal information in relation to Cognitive Cloud websites, applications, products, services, events, and experiences that reference this Privacy Notice (together, “Cognitive Cloud Offerings”).

This Privacy Policy does not apply to the “content” processed, stored, or hosted by our customers using Cognitive Cloud Offerings in connection with an Cognitive Cloud account. See the agreement governing your access to your Cognitive Cloud account and the Cognitive Cloud Data Privacy FAQ for more information about how we handle content and how our customers can control their content through Cognitive Cloud Offerings. This Privacy Notice also does not apply to any products, services, websites, or content that are offered by third parties or have their own privacy policy.

Personal Information We Collect

We collect your personal information in the course of providing Cognitive Cloud Offerings to you.

Here are the types of information we gather:

• Information You Give Us: We collect any information you provide in relation to Cognitive Cloud Offerings. Click here to see examples of information you give us.
• Automatic Information: We automatically collect certain types of information when you interact with Cognitive Cloud Offerings. Click here to see examples of information we collect automatically.
• Information from Other Sources: We might collect information about you from other sources, including service providers, partners, and publicly available sources. Click here to see examples of information we collect from other sources.

How We Use Personal Information

We use your personal information to operate, provide, and improve Cognitive Cloud Offerings. Our purposes for using personal information include:

• Provide Cognitive Cloud Offerings: We use your personal information to provide and deliver Cognitive Cloud Offerings and process transactions related to Cognitive Cloud Offerings, including registrations, subscriptions, purchases, and payments.
• Measure, Support, and Improve Cognitive Cloud Offerings: We use your personal information to measure use of, analyze performance of, fix errors in, provide support for, improve, and develop Cognitive Cloud Offerings.
• Recommendations and Personalization: We use your personal information to recommend Cognitive Cloud Offerings that might be of interest to you, identify your preferences, and personalize your experience with Cognitive Cloud Offerings.
• Comply with Legal Obligations: In certain cases, we have a legal obligation to collect, use, or retain your personal information. For example, we collect bank account information from Cognitive Cloud Marketplace sellers for identity verification.
• Communicate with You: We use your personal information to communicate with you in relation to Cognitive Cloud Offerings via different channels (e.g., by phone, email, chat) and to respond to your requests.
• Marketing: We use your personal information to market and promote Cognitive Cloud Offerings. We might display interest-based ads for Cognitive Cloud Offerings. To learn more, please read our Interest-Based Ads notice.
• Fraud and Abuse Prevention and Credit Risks: We use your personal information to prevent and detect fraud and abuse in order to protect the security of our customers, Cognitive Cloud, and others. We may also use scoring methods to assess and manage credit risks.
• Purposes for Which We Seek Your Consent: We may also ask for your consent to use your personal information for a specific purpose that we communicate to you.

How We Share Personal Information

Information about our customers is an important part of our business and we are not in the business of selling our customers’ personal information to others. We share personal information only as described below.

• Transactions Involving Third Parties: We make available to you services, software, and content provided by third parties for use on or through Cognitive Cloud Offerings. You can tell when a third party is involved in your transactions, and we share information related to those transactions with that third party. For example, you can order services, software, and content from sellers using the Cognitive Cloud Marketplace and we provide those sellers information to facilitate your subscription, purchases, or support.
• Third-Party Service Providers: We employ other companies and individuals to perform functions on our behalf. Examples include: delivering Cognitive Cloud hardware, sending communications, processing payments, assessing credit and compliance risks, analyzing data, providing marketing and sales assistance (including advertising and event management), conducting customer relationship management, and providing training. These third party service providers have access to personal information needed to perform their functions, but may not use it for other purposes. Further, they must process that information in accordance with this Privacy Policy and as permitted by applicable data protection law.
• Business Transfers: As we continue to develop our business, we might sell or buy businesses or services. In such transactions, personal information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Policy (unless, of course, the individual consents otherwise). Also, in the unlikely event that Cognitive Cloud or substantially all of its assets are acquired, your information will of course be one of the transferred assets.
• Protection of Us and Others: We release account and other personal information when we believe release is appropriate to comply with the law, enforce or apply our terms and other agreements, or protect the rights, property, or security of Cognitive Cloud, our customers, or others. This includes exchanging information with other companies and organizations for fraud prevention and detection and credit risk reduction.
• At Your Option: Other than as set out above, you will receive notice when personal information about you might be shared with third parties, and you will have an opportunity to choose not to share the information.

Location of Personal Information

Underlings Private Limited is located in Singapore, and our affiliated companies are located throughout the world. Depending on the scope of your interactions with Cognitive Cloud Offerings, your personal information may be stored in or accessed from multiple countries, including the United States. Whenever we transfer personal information to other jurisdictions, we will ensure that the information is transferred in accordance with this Privacy Policy and as permitted by applicable data protection lCognitive Cloud.

How We Secure Information

At Cognitive Cloud, security is our highest priority. We design our systems with your security and privacy in mind.

• We maintain a wide variety of compliance programs that validate our security controls. Click here to learn more about our compliance programs.
• We protect the security of your information during transmission to or from Cognitive Cloud websites, applications, products, or services by using encryption protocols and software.
• We follow the Payment Card Industry Data Security Standard (PCI DSS) when handling credit card data.
• We maintain physical, electronic, and procedural safeguards in connection with the collection, storage, and disclosure of personal information. Our security procedures mean that we may request proof of identity before we disclose personal information to you.

Internet Advertising and Third Parties

Cognitive Cloud Offerings may include third-party advertising and links to other websites and applications. Third party advertising partners may collect information about you when you interact with their content, advertising, or services. For more information about third-party advertising, including interest-based ads, please read our Interest-Based Ads notice.

Access and Choice

You can view, update, and delete certain information about your account and your interactions with Cognitive Cloud Offerings. Click here for a list of examples of information that you can access. If you cannot access or update your information yourself, you can always contact us for assistance.

You have choices about the collection and use of your personal information. Many Cognitive Cloud Offerings include settings that provide you with options as to how your information is being used. You can choose not to provide certain information, but then you might not be able to take advantage of certain Cognitive Cloud Offerings.

• Account Information: If you want to add, update, or delete information related to your account, please go to the Cognitive Cloud Management Console. When you update or delete any information, we usually keep a copy of the prior version for our records.
• Communications: If you do not want to receive promotional messages from us, please unsubscribe or adjust your communication preferences in the Cognitive Cloud Management Console or the Cognitive Cloud Email Preference Center. If you do not want to receive in-app notifications from us, please adjust your notification settings in the app or your device.
• Advertising: If you don’t want to see interest-based ads, please adjust your Advertising Preferences.
• Browser and Devices: The Help feature on most browsers and devices will tell you how to prevent your browser or device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether.

Children’s Personal Information

We don’t provide Cognitive Cloud Offerings for purchase by children. If you’re under 18, you may use Cognitive Cloud Offerings only with the involvement of a parent or guardian.

Retention of Personal Information

We keep your personal information to enable your continued use of Cognitive Cloud Offerings, for as long as it is required in order to fulfill the relevant purposes described in this Privacy Policy, as may be required by law (including for tax and accounting purposes), or as otherwise communicated to you. How long we retain specific personal information varies depending on the purpose for its use, and we will delete your personal information in accordance with applicable law.

Contacts, Notices, and Revisions

If you have any concern about privacy at Cognitive Cloud or want to contact one of our data controllers, please contact us with a thorough description, and we will try to resolve the issue for you. You may also contact us at the address below:

Underlings Private Limited
68 Circular Road
#02-01
Singapore (049422)
Attention: Arun Makhija

If you interact with Cognitive Cloud Offerings on behalf of or through your organization, then your personal information may also be subject to your organization’s privacy practices, and you should direct privacy inquiries to your organization.

Our business changes constantly, and our Privacy Policy may also change. You should check our website frequently to see recent changes. You can see the date on which the latest version of this Privacy Policy was posted. Unless stated otherwise, our current Privacy Policy applies to all personal information we have about you and your account. We stand behind the promises we make, however, and will never materially change our policies and practices to make them less protective of personal information collected in the past without informing affected customers and giving them a choice.

Examples of Information Collected

Information You Give Us

You provide information to us when you:

• search for, subscribe to, or purchase Cognitive Cloud Offerings;
• create or administer your Cognitive Cloud account (and you might have more than one account if you have used more than one email address when using Cognitive Cloud Offerings);
• configure your settings for, provide data access permissions for, or otherwise interact with Cognitive Cloud Offerings;
• register for or attend an Cognitive Cloud event;
• purchase or use content, products, or services from third-party providers through the Cognitive Cloud Marketplace (or other similar venues operated or provided by us);
• offer your content, products, or services on or through Cognitive Cloud Offerings or the Cognitive Cloud Marketplace (or other similar venues operated or provided by us);
• communicate with us by phone, email, or otherwise;
• complete a questionnaire, a support ticket, or other information request forms;
• post on Cognitive Cloud websites or participate in community features; and
• employ notification services.

Depending on your use of Cognitive Cloud Offerings, you might supply us with such information as:

• your name, email address, physical address, phone number, and other similar contact information;
• payment information, including credit card and bank account information;
• information about your location;
• information about your organization and your contacts, such as colleagues or people within your organization;
• usernames, aliases, roles, and other authentication and security credential information;
• content of feedback, testimonials, inquiries, support tickets, and any phone conversations, chat sessions and emails with or to us;
• your image (still, video, and in some cases 3-D), voice, and other identifiers that are personal to you when you attend an Cognitive Cloud event or use certain Cognitive Cloud Offerings;
• information regarding identity, including government-issued identification information;
• corporate and financial information; and
• VAT numbers and other tax identifiers.

Automatic Information

We collect information automatically when you:

• visit, interact with, or use Cognitive Cloud Offerings (including when you use your computer or other device to interact with Cognitive Cloud Offerings);
• download content from us;
• open emails or click on links in emails from us; and

• interact or communicate with us (such as when you attend an Cognitive Cloud event or when you request customer support). Examples of the information we automatically collect include:

• network and connection information, such as the Internet protocol (IP) address used to connect your computer or other device to the Internet and information about your Internet service provider;

• computer and device information, such as device, application, or browser type and version, browser plug-in type and version, operating system, or time zone setting;
• the location of your device or computer;
• authentication and security credential information;
• content interaction information, such as content downloads, streams, and playback details, including duration and number of simultaneous streams and downloads;
• Cognitive Cloud Offerings metrics, such as offering usage, occurrences of technical errors, diagnostic reports, your settings preferences, backup information, API calls, and other logs;
• the full Uniform Resource Locators (URL) clickstream to, through, and from our website (including date and time) and Cognitive Cloud Offerings, content you viewed or searched for, page response times, download errors, and page interaction information (such as scrolling, clicks, and mouse-overs);
• email addresses and phone numbers used to contact us.

Information from Other Sources

Examples of information we receive from other sources include:

• marketing, sales generation, and recruitment information, including your name, email address, physical address, phone number, and other similar contact information;
• subscription, purchase, support, or other information about your interactions with products and services offered by us, our affiliates (such as Cognitive Cloud training courses), or third parties (such as products offered through the Cognitive Cloud Marketplace) in relation to Cognitive Cloud Offerings;
• search results and links, including paid listings (such as Sponsored Links); and
• credit history information from credit bureaus.

Information You Can Access

Examples of information you can access through Cognitive Cloud Offerings include:

• your name, email address, physical address, phone number, and other similar contact information;
• usernames, aliases, roles, and other authentication and security credential information;
• your subscription, purchase, usage, billing, and payment history;
• payment settings, such as payment instrument information and billing preferences;
• tax information;
• email communication and notification settings;

Customers can access the information above through Cognitive Cloud Offerings, such as the Cognitive Cloud Dashboard.