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Privacy Policy

Updates February 23, 2026

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Cognition Med LLC (“Cognition Med,” “we” or “us”) is committed to protecting the privacy and security of your personally identifying information. We have prepared this Privacy Policy to explain how we collect, use, protect and disclose your Personal Information, Usage Data and Message Data (as those terms are defined below) when you use our mobile application (the “Services”). This Privacy Policy also explains how you can manage your information preferences. By using the Services, you acknowledge our Privacy Policy.

If you are a user or customer of Cognition Med, this Privacy Policy governs the limited personal information that you share in order to set up an account and access our tools, products, dashboard, and other services in accordance with our Terms of Service.

Please note that this Privacy Policy does not apply to the privacy practices of third parties whose links may appear on or through the Services. We are not responsible for the content or privacy practices of third parties or other users. We recommend that you exercise caution before you voluntarily disclose personally identifiable information to other users, on publicly accessible or displayable parts of the Service, or through third-party links on third-party websites or platforms.

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1. INFORMATION WE COLLECT; PERSONAL INFORMATION; OTHER TYPES OF DATA

ACCOUNT DATA

When you create an account and register, we collect information that may personally identify you, such as your name, address, mobile telephone number, e-mail addresses and other information that you provide to us (“Personal Information”). You may be asked to provide us with certain additional Personal Information when you register to use the Services and at other times. The decision to provide this information is voluntary. However, if you choose not to provide the requested information, you may not be able to use certain features of the Services, or the services in totality.

If you provide your third-party account credentials to us via a single-sign-on integration or otherwise sign in to the Services through a third-party site or service, you understand some content and/or information in those accounts (“Third Party Account Information”) may be transmitted into your account with us if you authorize such transmissions, and that Third Party Account Information transmitted to our Services is covered by this Privacy Policy.

 

USAGE DATA

We automatically collect usage information that allows us to collect information regarding how users access and use the Services (“Usage Data”). For example, when you download and use Services such as Coltrain, we automatically collect information on the type of device you use and the device identifier (or “UDID”). Additionally, each time you use the Services, we automatically collect information regarding your workflow within the app, the time and duration of your app usage, how you best communicate within the app, crash logs and other information relating to your use of the Services. We use this information to analyze trends, administer the Services, troubleshoot any user problems, and to enhance and update the Services.

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MESSAGE DATA

When you send or receive messages using our Services, we may temporarily process and store your messages (“Message Data”), in order to provide these Services to you. This data is transmitted at the User’s discretion, and under the relevant professional guidance specific to your use of the Services, and as outlined in the End Users License Agreement (EULA).

Users are encouraged to use standard precautions for the inclusion of PHI in case discussions. Meta data relevant to Service functions may be used for analysis. This data helps enhance services provided by Cognition Med LLC to its Users.

We respect the privacy of the data stored with Cognition Med. We neither intentionally process the data to extract personally identifiable information nor do we share the stored data with any third-party entities, agencies, or businesses that are not affiliated with Cognition Med. We ensure encryption of data in transit using SSL and ensure encryption of data at rest by storing data in encrypted database instances.

 

2. HOW WE USE THE INFORMATION WE COLLECT

BUSINESS OPERATION

We use the information we collect for internal purposes only. We do not sell or rent information about you. We will not disclose information to third parties without your consent, except as explained in this Privacy Policy. We are committed to safeguarding your privacy. We will ensure that your information is protected and remains within the secure confines of our infrastructure, thereby upholding our commitment to your privacy and data security.

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AI POLICY

Cognition Med processes Usage Data and Message Data solely to deliver, operate, secure, and improve the performance, reliability, and safety of the Services provided to the Customer. Cognition Med does not use identifiable patient information, protected health information (PHI), or customer-confidential data to train or fine-tune machine learning or large language models. Customer Data is used only for service delivery, system monitoring, and quality assurance. Where permitted by applicable law and contractual agreements, Cognition Med may use data that has been de-identified and aggregated in accordance with HIPAA de-identification standards or other applicable regulatory requirements to evaluate system performance, enhance usability, improve clinical workflow support, and strengthen product reliability.

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Artificial Intelligence (“AI”) refers to machine-based systems that analyze inputs to generate predictions, recommendations, classifications, or natural language outputs that support healthcare operations and clinical workflows. AI capabilities used by Cognition Med may include machine learning, natural language processing, and clinical decision support technologies designed to assist human decision-making. Cognition Med does not use Customer Data to develop generalized models for third-party use or commercial resale, and any insights derived from de-identified, aggregated data are applied solely to improve system safety, functionality, and effectiveness.

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SUPPORT SERVICES

Cognition Med may use your Personal Information to contact you regarding the Services. For example, we may, with your permission, message you to let you know about new releases, patches and other updates to the Services.

From time to time, we may establish business relationships with other businesses that we believe are trustworthy and who have confirmed that their privacy practices are consistent with ours (“Service Providers”). For example, we may contract with Service Providers to provide certain services, such as hosting and maintenance. We provide our Service Providers with only the information necessary for them to perform these services. Each Service Provider must agree to use reasonable security procedures and practices, appropriate to the nature of the information involved, to protect your Personal Information and Message Data from unauthorized access, use or disclosure. Service Providers are prohibited from using Personal Information or Message Data in any manner other than as specified by us.

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LOGGING STATISTICS Like most website operators, our servers automatically collect certain types of non-personally identifying, technical information, such as the browser type, language preference, referring site, and the date and time of each visitor request. This includes information such as:

  • What website you came from to get here;

  • What portions of our website you access;

  • How long you stay for; and

  • What kind of device you’re using

We use this information to better understand how our visitors use our website and to maintain Services.

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LOCATION INFORMATION & IP ADDRESSES We collect very limited personal data. If you fill out a form with your name and email address, we do link the IP address and device information to you. Additionally, we collect IP addresses and convert them to location for (1) security monitoring (2) supporting some features, such as IP whitelisting, country level location whitelisting, and (3) Delivering location-based help and website details.

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LOCALE PREFERENCES AND DEVICE INFORMATION When you use our services or products, we may automatically collect certain information from your device, its software, and your activity using our services or products. This may include information you search for on our website, locale preferences, identification numbers associated with your devices, your mobile carrier, date and time stamps associated with transactions, metadata, your Internet Service Provider, files viewed on our site, operating system, and clickstream data.

 

DATA AGGREGATION In addition to the other uses described in this policy, you agree that we may extract and use information from the information you disclose for the purposes of aggregating data in a non-identifiable method. This aggregated data may be used internally to improve services or without limitation, to develop, analyze, combine, or publish the aggregated data for commercial purposes.

 

COOKIES Your use of certain services may result in the assignment and storage of session cookies by Cognition Med and analytics tools to recognize your access privileges and generally track user preferences. A cookie is a text file that is placed on the hard disk of your computer or mobile device by a server. Session cookies expire when you end your session and close your browser interface. Cookies cannot be used to run programs or deliver viruses to your computer or mobile device. Cookies are uniquely assigned to you and can only be read by a server in the domain that issued the cookie to you. Visitors who do not wish to have cookies placed on their computers or mobile devices should deny Cookies by configuring their respective browsers to do so. If Cookies are denied, certain features of our services may not function properly.

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3. HOW WE PROTECT THE INFORMATION WE COLLECT

Cognition Med is committed to protecting the security of your information. We employ what we believe are industry-best security measures designed to protect your information from unauthorized access. Regardless of efforts, no data transmission over the Internet or other network, including any of Cognition Med’s services, can be guaranteed to be secure. Accordingly, we cannot and do not guarantee the absolute security of any information you transmit on or through the Services, and any information you transmit is sent at your own risk. Cognition Med fully and absolutely disclaims all liability related to the security of such information. We encourage you to help us by also taking precautions to protect your personal data when you use the services. Change your account password often, using a combination of letters, numbers, and characters, and make sure you use a secure connection. We also recommend enabling two-factor authentication for signing into your account.

We will retain your personal information for as long as needed for the purposes described above and/or as required by law. A user may request access to certain data about themselves by emailing support@coltrain.io.

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4. HOW WE USE OR SHARE YOUR INFORMATION

Cognition Med takes all measures reasonably necessary to protect against the unauthorized access, use, alteration or destruction of potentially personally identifying information. We disclose potential personally identifying information only on an as needed (or required) basis as follows:

  1. To our personnel that: (i) need to know that information in order to process it on our behalf or to provide the services; and (ii) that have expressly agreed not to disclose it to others. Note* Some of those employees, and contractors may be located outside of your home country; by using the services you consent to the transfer of such information to them.

  2. As required by law such as to comply with a subpoena or similar legal process. To the extent we are legally permitted to do so, we will take commercially reasonable steps to notify you if we are required to provide your personal information to third parties as part of a legal process.

  3. When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a written government request.

  4. In the event of a merger, acquisition, or any form of sale of some or all of our assets, we will ensure that the acquiring organization agrees to protect personal information in accordance with the commitments we have made in this Privacy Notice, and that the acquiring organization will provide notice before personal information, customer information, or business information becomes subject to a different privacy notice.

  5. To any other third party with your prior consent to do so. We do not generally sell your personal information to third parties.

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5. YOUR INFORMATION IS MAINTAINED IN THE UNITED STATES

Please be aware that we process and store all information in the United States. By using the Services, you agree that the collection, use, transfer, and disclosure of your information and communications will be governed by the applicable laws in the United States.

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6. MISCELLANEOUS ACCURACY AND RETENTION

You can always review, correct, update, or change your Personal Information. Upon your request, we will: (1) correct, update or change your Personal Information; (2) stop sending you messages if you wish to opt out of our direct marketing efforts; and/or (3) disable your account to prevent any future activity through that account. You may make any of these requests by emailing the request to support@coltrain.io. If you have questions or concerns regarding this Privacy Policy, please e-mail them to support@coltrain.io. Please do not email any sensitive information.

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7. COMMUNICATIONS FROM US

If you have provided an email with us for access and use of our services, we may occasionally send you an email to tell you about new features, solicit your feedback, or just keep you up to date with what’s going on with Cognition Med and our services. We primarily use our various product blogs and support documentation to communicate this type of information, so we expect to keep this type of email to a minimum.

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8. THIRD PARTY SERVICES

We use various third-party services to create the best experience for users, to deliver on certain logistics services, and for improving existing products and services. Some third party services use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service. We use Google Cloud Provider, Kubernetes and Microsoft Azure to store information and host services. We use various third-party services that collect and analyze information about your use of our site. Among others, we use Amplitude and Google Analytics for app and website use and traffic analysis. We also use various services to ensure user success and improved relationship management.

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9. PRIVACY OF MINORS

We do not promote or offer the Services for use by anyone under the age of 18 (“minors”). Cognition Med does not knowingly solicit or collect personal information from minors, and we will not knowingly link to any third-party website or platform or host any customer sites that solicit or collect personal information from minors. If you believe that a minor has disclosed personal information to us or that we have linked to such a third-party or user website or platform, please contact us at support@cognition.io.

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10. ADDITIONAL INFORMATION FOR INTERNATIONAL USERS

If you are visiting this website and/or accessing the Services from outside the United States, please be aware that you are sending information (including Personal Information) to the United States where our servers are located. This information may be transferred within the United States or back out of the United States to other countries outside of your country of residence, depending on the type of information and how its stored by us. These countries (including the United States) may not necessarily have data protection laws as comprehensive or protective as those in your country of residence, however, our collection, storage and use of your personal information will at all times be governed by this Privacy Policy. Notwithstanding the foregoing, this service is not available to international users.

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11. BUSINESS TRANSFERS

If the ownership of Cognition Med substantially changes, such that all of its assets were acquired, or merged into another entity, or in the unlikely event that we enter bankruptcy, you understand that any stored personally identifying, and non-personally identifying information and data will likely be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur and that any acquirer or merging entity of Cognition Med may continue to use your personal information as set forth in this policy.

 

12. YOUR RIGHTS UNDER THE CCPA (EXTENDED TO ALL USERS)

The California Consumer Privacy Act (CCPA) and some other state laws provide you with fundamental rights. Due to our commitment to privacy, we have extended those data subject rights to persons in all jurisdictions.

  • Right to be forgotten (“Right to Erasure”): This right provides you with the ability to ask for the deletion of your data. This is not an absolute right and depends on our retention schedule in line with other applicable laws.

  • Right to Information: This right provides that you may ask us for information about what personal data is being processed and the rationale for such processing.

  • Right to Access: This right provides you with the ability to get access to your personal data that is being processed and request copies of it.

  • Right to Rectification: This right provides you with the ability to ask for modifications to your personal data in case you believe it is not up to date or accurate.

  • Right to Withdraw Consent: This right provides you with the ability to withdraw a previously given consent for processing.

  • Right to Object: This right allows you to object to certain types of data processing, such as for statistical purposes related to research or tasks in the public interest.

  • Right to Data Portability: This right provides you with the ability to ask for the transfer of your personal data back to you or to another service provider in a machine-readable format.

  • Right to Limit Use and Disclosure of Sensitive Personal Information: You have the right to direct us to limit our use of your sensitive personal information to that which is necessary to perform the expected services.

If you would like to exercise any of the above rights, please contact our support team at support@coltrain.io.

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13. CHANGES TO THE PRIVACY POLICY

We may periodically change this Privacy Policy. If we decide to change this Privacy Policy, we will inform you by posting the revised Privacy Policy on our website or within the messaging application. Those changes become effective upon posting, the date of which is shown as the “Revised On” date in the revised Privacy Policy. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is collected. By continuing to use the Services, you agree to be bound by the revised Privacy Policy.

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14. CONTACT APPROPRIATE AUTHORITY

Should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you have the right to contact a regulatory body or data protection authority in relation to your complaint.

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